As the financial services sector continues to evolve in response to emerging cyber threats, the impending retirement of the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Assessment Tool (CAT) by the end of 2025 necessitates a strategic shift for credit unions and community banks. This transition presents an opportunity to adopt more dynamic and comprehensive cybersecurity frameworks that align with current regulatory expectations and industry best practices.

The Transition from FFIEC CAT

Since its introduction in 2015, the FFIEC CAT has been instrumental in helping financial institutions assess their cybersecurity preparedness. However, with the increasing complexity of cyber threats and the need for more adaptable risk management approaches, the FFIEC has decided to phase out the CAT. This decision encourages institutions to transition to frameworks offering greater flexibility and scalability in managing cybersecurity risks.

Embracing NIST Cybersecurity Framework (CSF) 2.0

The National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) 2.0 (released in February 2024), has emerged as a preferred choice among financial institutions seeking to enhance their cybersecurity posture. This updated framework introduces six core functions providing a comprehensive approach to managing cybersecurity risks: 

1. Govern
2. Identify
3. Protect
4. Detect
5. Respond
6. Recover

The addition of the "Govern" function emphasizes the importance of integrating cybersecurity into organizational governance and risk management processes. This aligns with regulatory expectations and supports institutions in establishing clear policies, roles and responsibilities related to cybersecurity.

Considering the CIS Critical Security Controls

For institutions seeking a more prescriptive approach, the Center for Internet Security (CIS) Critical Security Controls (CIS Controls) offers a prioritized set of 18 actions designed to mitigate the most prevalent cyber threats. These controls are organized into implementation groups, allowing organizations to tailor their cybersecurity efforts based on size, resources and risk profile.

The CIS controls are widely recognized and have been adopted by various organizations, including financial institutions, to strengthen cybersecurity defenses. While they provide specific technical guidance, they can also complement broader frameworks like the NIST CSF, by offering actionable steps to implement strategic objectives.

Strategic Considerations for Framework Adoption

When selecting a cybersecurity framework, credit unions and community banks should evaluate:

• Organizational Complexity: Larger institutions with complex IT infrastructures may benefit from the comprehensive nature of NIST CSF 2.0.
• Resource Availability: Smaller institutions with limited resources might find the structured guidance of the CIS Controls more manageable.
• Regulatory Alignment: Both frameworks align with regulatory expectations, but institutions should assess which framework best fits their specific compliance requirements.
• Integration Potential: Consider how the chosen framework can integrate with existing risk management processes and other compliance initiatives.

Recommended Actions for Transition

To navigate the transition from the FFIEC CAT effectively, consider these options:

1. Conduct a Gap Analysis: Assess current cybersecurity practices against the chosen framework to identify areas for improvement.
2. Engage Stakeholders: Involve executive leadership, IT personnel and other relevant parties to ensure organizational buy-in and support.
3. Develop a Transition Plan: Outline a clear roadmap with defined timelines, responsibilities and resource allocations.
4. Implement Training Programs: Educate staff on new policies, procedures and controls associated with the adopted framework.
5. Monitor and Review: Establish metrics to evaluate the effectiveness of the new framework and make adjustments as necessary.

Manage Risks with Ease

The retirement of the FFIEC CAT marks a pivotal moment for credit unions and community banks to reassess and enhance their cybersecurity strategies. By adopting frameworks like NIST CSF 2.0 or the CIS Critical Security Controls, institutions can better position themselves to manage evolving cyber risks and meet regulatory expectations. Proactive planning and implementation will be key to ensuring a smooth transition and strengthening the overall cybersecurity posture.

Is your institution seeking assistance in selecting or implementing a cybersecurity framework? Doeren Mayhew’s cybersecurity and IT advisory pros stand ready to assist with tailored solutions to meet your institution's unique needs.