Back to BlogA Guide to FFIEC CAT Compliance for Financial Institutions
in Compliance
Most financial institutions know the headache of meeting compliance all too well. Businesses with smaller IT and security teams can especially feel the pressure as they prove to external stakeholders that they take these regulations seriously.
But what if these resource-strapped teams saw compliance as an opportunity for strengthening cybersecurity rather than a box to check? This shift in mindset might seem counterintuitive, but in the long run, it can help financial institutions use their resources more strategically and prepare for any regulatory changes down the road.
Terra Cooke, a compliance and security expert, spoke about the importance of viewing compliance as a security enabler at a Blumira webinar. She said,
“If you’re just going through and saying, ‘I’m going to just do these things because that’s what [the framework] told me to do’ and nothing more and nothing less, you’re probably going to leave yourself with more holes than not…instead, focus on building a good solid security program and when you’re thinking about your compliance controls, ask, ‘how do those two blend well together?’”
When financial institutions with limited resources take this advice to heart and connect the dots between compliance regulations and actionable cybersecurity practices, they will use resources more effectively and keep their businesses safe in the long run. In this blog, we’ll look at the FFIEC cybersecurity assessment tool and cover a few practical tips for turning this list of regulations into obtainable cybersecurity initiatives.
An overview of FFIEC CAT
All financial institutions will find themselves working to meet Federal Financial Institution Examining Council regulations at some point. FFIEC guidelines generally focus on IT management, cybersecurity, and the protection of consumer financial data.
The FFIEC also offers a voluntary cybersecurity assessment tool (CAT) that maps closely to the requirements laid out by the mandatory FFIEC Information Technology (IT) Examination Handbook. Financial institutions can leverage CAT to meet general FFIEC requirements and, as mentioned, to springboard into a better approach to cybersecurity. CAT hones in on two significant activities:
- Assessing your institution’s inherent risk profile
- Managing and evaluating your institution’s cybersecurity maturity level in five distinct areas:
- Domain 1: Cyber Risk Management and Oversight
- Domain 2: Threat Intelligence and Collaboration
- Domain 3: Cybersecurity Controls
- Domain 4: External Dependency Management
- Domain 5: Cyber Incident Management and Resilience
3 actionable tips for meeting FFIEC CAT
Meeting CAT not only brings the opportunity to meet these two requirements but also to establish repeatable, consistent processes that can be built upon easily. Here are a few tips for transforming FFIEC CAT requirements into actionable security initiatives.
1. Know what’s in your organization’s purview and what risk it entails.
The first part of FFIEC CAT is about finding and assessing inherent risk within your organization. It presents five key areas that you should investigate:
- Technologies and connection types, such as wireless access, networks, cloud services, personal devices, etc.
- Delivery channels for providing financial services, such as mobile apps, ATMs, etc.
- Online/mobile products and technology services, such as debit/credit cards, wireless transfers, ACH, etc.
- Organizational characteristics, such as employee cybersecurity practices, IT environment, operation locations, etc.
- External threats, including all attempted and successful attacks and their level of sophistication
The key here is to compile all this data into a single location, putting security information on cloud infrastructure, endpoint devices, and applications together. Implementing SIEM logging—especially a solution that can integrate with visibility tools like cloud access security broker (CASB) and security orchestration, automation, and response (SOAR)—is a great place to start centralizing all of this data into one place.
2. Understand which risks matter to your specific organization, then take action based on these priorities.
Meeting part 1 of FFIEC CAT goes beyond just knowing which assets you own and which risks they pose. It also focuses on assessing the severity of each risk related to your unique organizational structure and then taking action to mitigate these security issues. This process of fixing vulnerabilities and threats based on organizational priorities also fits some of the criteria listed in part 2 of CAT. For example, under the section Domain 2: Threat Intelligence and Collaboration, CAT reminds us that a key part of monitoring is to also “identify threats that are specific to the institution.”
CAT also explains that you shouldn’t just identify these threats and call it a day but also find ways to fix the risk effectively. Domain 5: Cyber Incident Management and Resilience states that it’s vital to “identify, prioritize, respond to, and mitigate the effects of internal and external threats and vulnerabilities.” Domain 3: Cybersecurity Controls also focuses on implementing actionable techniques for fixing the most pressing security threats at your organization in a repeatable, measurable way.
Sound overwhelming? Well, it doesn’t have to be. When your organization can clearly understand which risks are worth spending time on and which aren’t, it’s far easier to, well, fix things.
Here are a few actionable steps you can take to narrow down your list of risks and fix the ones that matter most:
- Get the easy fixes out of the way by using automation that automatically blocks malicious source IPs or domains or cuts off infected endpoints.
- Tune your SIEM detection rules to minimize false positives or irrelevant alerts (or use an intelligent solution that can do so).
- Leverage automated playbooks to make it much easier to mitigate risks.
3. Make reporting a quick and straightforward activity for your team.
Almost every focus area of FFEIC CAT ties back to reporting to the right stakeholders and creating open lines of communication across your organization. For example, escalation & reporting is an assessment factor for Domain 5, Cyber Incident Management and Resilience.
Plus, information sharing, described as “establishing relationships with peers and information-sharing forums and how threat information is communicated to those groups as well as internal stakeholders,” is highlighted in Domain 2 Threat Intelligence and Collaboration. Since reports play such an integral role in meeting CAT, it stands to reason that you should make the reporting process as painless as possible for your team.
You can do so by…
- Maintaining a year of data retention
- Implementing a centralized dashboard that is compatible with your security tech stack
- Leveraging security reporting tools that make it as simple as possible to build out reports
The Blumira XDR platform makes it simple to comply with FFEIC CAT
Blumira offers a budget-friendly XDR platform that can support all three of these actionable tips. To learn more about meeting compliance with Blumira, discover how we also help organizations meet NCUA (National Credit Union Administration) requirements.