How to Adapt to the Retirement of the FFIEC Cybersecurity Assessment Tool

You’ve likely heard the news…the Federal Financial Institutions Examination Council (FFIEC) is officially retiring its Cybersecurity Assessment Tool (CAT). For many community banks across the Midwest, this tool has been a staple in preparing for IT exams, measuring cyber maturity, and demonstrating due diligence to regulators. But now that it’s going away, the question remains - what will take its place?

The CAT’s structured, easy-to-follow format was especially useful for banks with limited internal IT resources - providing a common language between your tech teams, leadership, and auditors. While the FFIEC Cybersecurity Assessment Tool may be retiring, your need to evaluate and demonstrate your institution’s cybersecurity posture certainly isn’t. Regulators will still expect you to have a strong cybersecurity risk assessment process.

Why is the FFIEC Cybersecurity Assessment Tool being retired?

Since 2015, the FFIEC Cybersecurity Assessment Tool has served the banking industry well, but it hasn’t kept up with the evolving threat landscape or the increasing demands for more flexible and modern risk assessment tools. The FFIEC announced the phase-out of the CAT to encourage institutions to adopt more adaptable frameworks that are better aligned with today’s cybersecurity best practices.

While the FFIEC will no longer update or support the CAT, they’ve made it clear that cybersecurity assessments are not optional. Regulators will still be asking questions - and expecting answers - about your cybersecurity maturity, risk management strategy, and incident response readiness.

What should you look for in a replacement?

Here are three things your next cybersecurity assessment tool should offer:

1. Map to industry frameworks – It should align with widely accepted standards like the NIST Cybersecurity Framework or CIS Controls, which regulators increasingly expect institutions to follow.
2. Customizable – Your bank is unique. You need a tool that allows you to tailor the assessment to your institution’s size, complexity, and risk profile.
3. Audit-ready reporting – When examiners ask how you’re managing cybersecurity risk, your tool should make it easy to generate reports that tell a clear and complete story.

The CAT was a useful tool for many years, but its phase-out is a perfect chance to upgrade to tools that better match today’s cybersecurity needs. Picking the right option now lets you stay ahead of the game, meet regulatory expectations, and go through the transition smoothly.

CISA’s CSET is a solid option

At Locknet, we think the Cyber Security Evaluation Tool (CSET) developed by the Cybersecurity and Infrastructure Security Agency (CISA) can be a good option for our banking clients. It’s a free, well-supported tool that helps financial institutions evaluate their cybersecurity posture based on recognized industry standards.

Unlike the FFIEC Cybersecurity Assessment Tool, CSET is regularly updated to reflect emerging threats and current best practices. It’s also scalable, which makes it ideal for small and mid-sized banks looking for a clear, defensible, and thorough way to assess their cybersecurity readiness.

Looking ahead

You’ve known the CAT was on borrowed time, and now it’s official. Ultimately, choosing a new risk assessment framework is up to your bank’s specific needs. But the worst thing you can do is wait until your next exam to scramble for a replacement. Transitioning to a new tool today puts you in control of the process and helps ensure your bank remains audit ready.

If you’re unsure where to start, we’re here to help. As a Managed Security Service Provider, our team can assist with selecting, configuring, and implementing the right cybersecurity assessment solution for your institution’s unique needs. Contact us to schedule a consultation.