While the FFIEC is not endorsing any specific tool or framework, banks are encouraged to adopt established, standards-based approaches aligned with their risk profile and control environment. Institutions opting for custom-built frameworks may attract unnecessary regulatory scrutiny.

The ideal replacement for the CAT for banks should meet all criteria below:

• Based on a widely recognized cybersecurity framework (e.g., NIST Cybersecurity Framework)
  This ensures alignment with industry best practices, promotes consistency across institutions, and provides credibility with regulators and auditors.
• Maintained and regularly updated by a committed and reputable organization
  This keeps the framework current with emerging threats, regulatory changes, and evolving security standards, ensuring long-term relevance.
• Tailored to specific challenges, regulatory expectations, and risk profiles of the financial industry
  The framework should reflect the high-security standards and compliance obligations unique to financial institutions, including their exposure to cyber threats and customer data sensitivity.
• Supports structured assessment, tracking, and reporting of cybersecurity posture, including assessment-to-assessment comparison reports
  Financial institutions need the ability to evaluate their cybersecurity maturity over time, identify gaps, create an action plan for improvement, and demonstrate progress to stakeholders, including boards and regulators.
• Allow for customization to meet the unique needs of individual institutions
  Each financial institution has its own size, complexity, and risk appetite—the framework should be flexible enough to accommodate these differences without compromising structure or rigor.

Additional considerations:

• Consider partnering with subject matter experts to assist with the completion of the assessment and interpretation of the assessment results
  Because all the alternative frameworks differ significantly from the FFIEC CAT, implementation can be resource-intensive, requiring substantial time, effort, and expertise both initially and on an ongoing basis. Developing a prescriptive, results-driven action plan also hinges on accurately interpreting assessment results. Engaging experts can ease the implementation and maximize long-term impact.

To help with your evaluation, below is a comparison chart, and you can also download the checklist.

Alternatives Comparison Chart

*They anticipate releasing a financial sector-specific set of goals and updating to NIST CSF 2.0 at some point (estimated Winter 2025).

Once your bank has selected a preferred alternative, you need to develop a transition plan in advance of the CAT retirement in August 2025:

1. Engage internal stakeholders (e.g., IT, compliance, risk management, and internal audit) to evaluate tool fit and implementation requirements.
2. Transition to the framework and conduct a gap analysis comparing your most recent CAT assessment results with the results of your chosen framework.
3. Document framework choice rationale and communicate changes to your examiners and board of directors to demonstrate that you’ve implemented a risk-based, coordinated, and well-governed approach.
4. Follow these best practices when conducting assessments:Treat the assessment as a starting point: Use results to identify control gaps and define a roadmap toward your target cybersecurity maturity.Ensure reporting capability: Select a framework or tool that enables the production of clear, comprehensive reports for stakeholders, examiners, and the board.Expect ongoing updates: Choose frameworks supported by organizations committed to updating content to reflect evolving cyber threats and best practices.Prioritize flexibility: Institutions should be able to tailor the framework to their specific size, complexity, and risk profile.Be mindful of the transition process: The new framework should facilitate the mapping of your previous CAT assessment responses to the new framework to maintain assessment consistency, reduce duplication, and ease the transition.

By taking proactive steps to select and implement the right framework, you can ensure that your cybersecurity strategy remains robust, aligned with industry standards, and responsive to evolving threats.

View the checklist