Most bank boards struggle with cybersecurity oversight because they don’t know what questions to ask, how to interpret the answers or whether their security measures are actually working. Directors may approve cybersecurity budgets without understanding if those investments actually reduce risk, or they may review incident reports without grasping whether response times meet industry standards. They can describe their cybersecurity framework but often can’t explain what their institution does with the results. The challenge is compounded further when cybersecurity is presented as a jargon-filled IT issue rather than the business-critical risk it represents, creating a dangerous gap between regulatory expectations and board-level understanding that leaves institutions vulnerable not just to cyber threats but to regulatory scrutiny. Whether you’re a director seeking to understand what your institution’s NIST Cybersecurity Framework (CSF) or ISO framework results actually mean for your risk profile or an executive preparing risk dashboards, security briefings and incident reports for your board, the ultimate risk assessment strategy is to provide practical approaches that close the cybersecurity literacy gap. Board cybersecurity literacy doesn’t mean directors must become technical experts. But it does require structured questioning, clear reporting that translates technical risks into business impact and honest assessment of organizational maturity. The Uncomfortable Truth About Board Cybersecurity Literacy Here’s what I’ve observed after years of working with bank boards: Most of them generally don’t meet expectations when it comes to cybersecurity oversight. That’s not an indictment of their dedication or intelligence. It’s simply a recognition that cybersecurity has evolved faster than board education. Many directors can tell you which framework their institution uses — whether it’s the NIST CSF, ISO standards or something else. But when you dig deeper and ask what they’re actually doing with that framework, you often get blank stares. Completing an assessment means nothing if you can’t articulate what you learned from it and what you’re doing to improve. The critical question isn’t “Did we complete our assessment?” It’s “What have we done with the results?” The Framework Transition Challenge The Aug. 31, 2025, sunset of the FFIEC Cybersecurity Assessment Tool (CAT) forces smaller institutions to adopt more complex frameworks. The leap isn’t incremental … it’s substantial. But the transition is long overdue; many mature organizations should have already moved beyond the CAT’s simplified approach to adopt more comprehensive frameworks. YOUR BOARD’S CYBERSECURITY OVERSIGHT PROBABLY ISN’T GOOD ENOUGH BY STEVE SANDERS, CHIEF RISK OFFICER AND CHIEF INFORMATION SECURITY OFFICER, CSI 12
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