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. The CAT provided a simple rating system that scored your cybersecurity maturity from one to five across different domains like cyber risk management, controls and threat intelligence. The NIST CSF requires significantly more work: comprehensive risk assessments across five core functions, detailed control documentation and ongoing measurement of outcomes rather than simple numerical ratings. That makes it less user-friendly for small banks, but risk assessment should never be contingent on how easy it is to complete. Community banks also face a severe shortage of qualified cybersecurity professionals. This isn’t just an inconvenience; it’s a fundamental challenge that boards must address strategically. Smaller organizations may need to spend money bringing in external expertise to complete assessments. That’s not a sign of weakness. It’s a recognition that resource constraints make professional oversight frameworks even more critical. These knowledge gaps among bank boards are prominent. A director once told me their institution scored well on their cybersecurity assessment, but when I asked what specific improvements resulted from those findings, they couldn’t answer. That disconnect between completing an exercise and achieving real security maturity represents exactly what needs to be addressed to develop real cybersecurity preparedness. Five Essential Board Responsibilities Directors don’t need to understand the technical details of firewalls or encryption. But they do need to fulfill five essential oversight responsibilities: 1. Understand Your Security Posture Board members should ask management to explain the cybersecurity framework in plain English, request summaries of the security posture — both strengths and weaknesses — and understand the top five security improvement priorities for the coming year with specific, measurable goals. For executives preparing these briefings, present framework results as a narrative, not a checklist. Translate technical findings into business risks with a clear improvement roadmap. Your directors can’t provide effective oversight if they can’t understand what you’re telling them. 2. Ask the Right Questions The questions directors ask matter more than whether they understand every technical answer. Focus on these: How do we compare to peer institutions? What is the business impact associated with our three highest-rated risks? How do we validate that our controls are actually working? That last question is particularly important. Too many institutions assume that because they implemented a control, it must be working. Executives should come prepared with peer benchmarking data. Quantify risk in dollars and customer impact, not technical metrics. Include validation results, not just implementation status. 3. Set Clear Expectations Directors need to define the institution’s acceptable risk tolerance for different types of threats, establish a reporting 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?” NEBRASKA INDEPENDENT BANKER 15
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