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FFIEC Cybersecurity Assessment Tool

Overview for Chief Executive Officers and Boards of Directors

In light of the increasing volume and sophistication of cyber threats, the Federal Financial Institutions Examination Council1 (FFIEC) developed the Cybersecurity Assessment Tool (Assessment), on behalf of its members, to help institutions identify their risks and determine their cybersecurity preparedness. The Assessment provides a repeatable and measurable process for institutions to measure their cybersecurity preparedness over time. The Assessment incorporates cybersecurity-related principles from the FFIEC Information Technology (IT) Examination Handbook and regulatory guidance, and concepts from other industry standards, including the National Institute of Standards and Technology (NIST) Cybersecurity Framework.2

Benefits to the Institution

For institutions using the Assessment, management will be able to enhance their oversight and management of the institution’s cybersecurity by doing the following:

•Identifying factors contributing to and determining the institution’s overall cyber risk.

•Assessing the institution’s cybersecurity preparedness.

•Evaluating whether the institution’s cybersecurity preparedness is aligned with its risks.

•Determining risk management practices and controls that are needed or need enhancement and actions to be taken to achieve the desired state.

•Informing risk management strategies.

CEO and Board of Directors

The role of the chief executive officer (CEO), with management’s support, may include the responsibility to do the following:

•Develop a plan to conduct the Assessment.

•Lead employee efforts during the Assessment to facilitate timely responses from across the institution.

•Set the target state of cybersecurity preparedness that best aligns to the board of directors’ (board) stated (or approved) risk appetite.

•Review, approve, and support plans to address risk management and control weaknesses.

•Analyze and present results for executive oversight, including key stakeholders and the board, or an appropriate board committee.

1The FFIEC comprises the principals of the following: The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, and State Liaison Committee.

2A mapping is available in Appendix B: Mapping Cybersecurity Assessment Tool to the NIST Cybersecurity Framework. NIST reviewed and provided input on the mapping to ensure consistency with Framework principles and to highlight the complementary nature of the two resources.

FFIEC Cybersecurity Assessment ToolOverview for CEOs and Boards of Directors

Cybersecurity Maturity

• Cyber Incident Management and Resilience

maturity level. Management determines which declarative statements best fit the current practices of the institution. All declarative statements in each maturity level, and previous levels, must be attained and sustained to achieve that domain’s maturity level. While management can determine the institution’s maturity level in each domain, the Assessment is not designed to identify an overall cybersecurity maturity level. The figure below provides the five domains and assessment factors.

Training and

Culture

Management can review the institution’s Inherent Risk Profile in relation to its Cybersecurity Maturity results for each domain to understand whether they are aligned. The following table depicts the relationship between an institution’s Inherent Risk Profile and its domain Maturity Levels, as there is no single expected level for an institution. In general, as inherent risk rises, an institution’s maturity levels should increase. An institution’s inherent risk profile and maturity levels will change over time as threats, vulnerabilities, and operational environments change. Thus, management should consider reevaluating the institution’s inherent risk profile and cybersecurity maturity periodically and when planned changes can affect its inherent risk profile (e.g., launching new products or services, new connections).

Management can then decide what actions are needed either to affect the inherent risk profile or to achieve a desired state of maturity. On an ongoing basis, management may use the Assessment to identify changes to the institution’s inherent risk profile when new threats arise or when considering changes to the business strategy, such as expanding operations, offering new products and services, or entering into new third-party relationships that support critical activities. Consequently, management can determine whether additional risk management practices or controls are needed to maintain or augment the institution’s cybersecurity maturity.

Cybersecurity Management &

Oversight

•Is the institution’s cybersecurity

preparedness receiving the appropriate level of time and attention from management and the board or an appropriate board committee?

•Do the institution’s policies and procedures demonstrate management’s commitment to sustaining appropriate cybersecurity maturity levels?

•What is the ongoing process for gathering, monitoring, analyzing, and reporting risks?

•Who is accountable for assessing and managing the risks posed by changes to the business strategy or technology?

•Are the accountable individuals empowered with the authority to carry out these responsibilities?

•Do the inherent risk profile and cybersecurity maturity levels meet management’s business and risk management expectations? If there is misalignment, what are the proposed plans to bring them into alignment?

•How can management and the board, or an appropriate board committee, make this process part of the institution’s enterprise-wide governance framework?

Inherent Risk Profile

•What is the process for gathering and validating the information for the inherent risk profile and cybersecurity maturity?

•How can management and the board, or an appropriate board committee, support improvements to the institution’s process for conducting the Assessment?

•What do the results of the Assessment mean to the institution as it looks at its overall risk profile?

•What are the institution’s areas of highest inherent risk?

•Is management updating the institution’s inherent risk profile to reflect changes in activities, services, and products?

Cybersecurity Maturity

•How effective are the institution’s risk management activities and controls identified in the Assessment?

•Are there more efficient or effective means for attaining or improving the institution’s risk management and controls?

•What third parties does the institution rely on to support critical activities?

•What is the process to oversee third parties and understand their inherent risks and cybersecurity maturity?

•How does management validate the type and volume of attacks?

•Is the institution sharing threat information with peers, law enforcement, and critical third parties through information-sharing procedures?

Summary

FFIEC has developed the Assessment to assist management and the board, or an appropriate board committee, in assessing their institution’s cybersecurity preparedness and risk. For more information and additional questions to consider, refer to the FFIEC Cybersecurity Assessment General Observations on the FFIEC’s Web site.

Additional Resources

Overview for Chief Executive Officers and Boards of Directors

Appendix A: Mapping Baseline Statements to FFIEC IT Examination Handbook

Appendix B: Mapping Cybersecurity Assessment Tool to NIST Cybersecurity Framework

Appendix C: Glossary

User’s Guide

Overview

In light of the increasing volume and sophistication of cyber threats, the Federal Financial Institutions Examination Council1 (FFIEC) developed the Cybersecurity Assessment Tool (Assessment), on behalf of its members, to help institutions identify their risks and determine their cybersecurity maturity.

The content of the Assessment is consistent with the principles of the FFIEC Information Technology Examination Handbook (IT Handbook) and the National Institute of Standards and Technology (NIST) Cybersecurity Framework,2 as well as industry accepted cybersecurity

practices. The Assessment provides institutions with a repeatable and measureable process to inform management of their institution’s risks and cybersecurity preparedness.

The Assessment consists of two parts: Inherent Risk Profile and Cybersecurity Maturity. The

Inherent Risk Profile identifies the institution’s inherent risk before implementing controls. The Cybersecurity Maturity includes domains, assessment factors, components, and individual

declarative statements across five maturity levels to identify specific controls and practices that are in place. While management can determine the institution’s maturity level in each domain,

the Assessment is not designed to identify an overall cybersecurity maturity level.

To complete the Assessment, management first assesses the institution’s inherent risk profile

based on five categories:

∙Technologies and Connection Types

∙Delivery Channels

∙Online/Mobile Products and Technology Services

∙Organizational Characteristics

∙External Threats

Management then evaluates the institution’s Cybersecurity Maturity level for each of five

domains:

∙Cyber Risk Management and Oversight

∙Threat Intelligence and Collaboration

∙Cybersecurity Controls

∙External Dependency Management

∙Cyber Incident Management and Resilience

1The FFIEC comprises the principals of the following: The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, and State Liaison Committee.

2A mapping is available in Appendix B: Mapping Cybersecurity Assessment Tool to the NIST Cybersecurity Framework. NIST reviewed and provided input on the mapping to ensure consistency with Framework principles and to highlight the complementary nature of the two resources.

By reviewing both the institution’s inherent risk profile and maturity levels across the domains,

management can determine whether its maturity levels are appropriate in relation to its risk. If

not, the institution may take action either to reduce the level of risk or to increase the levels of maturity. This process is intended to complement, not replace, an institution’s risk management

process and cybersecurity program.

Background

The Assessment is based on the cybersecurity assessment that the FFIEC members piloted in

2014, which was designed to evaluate community institutions’ preparedness to mitigate cyber risks. NIST defines cybersecurity as “the process of protecting information by preventing, detecting, and responding to attacks.” As part of cybersecurity, institutions should consider

managing internal and external threats and vulnerabilities to protect infrastructure and information assets. The definition builds on information security as defined in FFIEC guidance.

Cyber incidents can have financial, operational, legal, and reputational impact. Recent high- profile cyber attacks demonstrate that cyber incidents can significantly affect capital and earnings. Costs may include forensic investigations, public relations campaigns, legal fees, consumer credit monitoring, and technology changes. As such, cybersecurity needs to be

integrated throughout an institution as part of enterprise-wide governance processes, information security, business continuity, and third-party risk management. For example, an institution’s

cybersecurity policies may be incorporated within the information security program. In addition, cybersecurity roles and processes referred to in the Assessment may be separate roles within the security group (or outsourced) or may be part of broader roles across the institution.

Completing the Assessment

The Assessment is designed to provide a measurable and repeatable process to assess an institution’s level of cybersecurity risk and preparedness. Part one of this Assessment is the

Inherent Risk Profile, which identifies an institution’s inherent risk relevant to cyber risks. Part two is the Cybersecurity Maturity, which determines an institution’s current state of

cybersecurity preparedness represented by maturity levels across five domains. For this Assessment to be an effective risk management tool, an institution may want to complete it periodically and as significant operational and technological changes occur.

Cyber risk programs build upon and align existing information security, business continuity, and disaster recovery programs. The Assessment is intended to be used primarily on an enterprise- wide basis and when introducing new products and services as follows:

∙Enterprise-wide. Management may review the Inherent Risk Profile and the declarative statements to understand which policies, procedures, processes, and controls are in place enterprise-wide and where gaps may exist. Following this review, management can determine appropriate maturity levels for the institution in each domain or the target state for Cybersecurity Maturity. Management can then develop action plans for achieving the target state.

∙New products, services, or initiatives. Using the Assessment before launching a new product, service, or initiative can help management understand how these might affect the institution’s inherent risk profile and resulting desired maturity levels.

Part One: Inherent Risk Profile

Part one of the Assessment identifies the institution’s inherent risk. The Inherent Risk Profile identifies activities, services, and products organized in the following categories:

∙Technologies and Connection Types. Certain types of connections and technologies may pose a higher inherent risk depending on the complexity and maturity, connections, and nature of the specific technology products or services. This category includes the number of Internet service provider (ISP) and third-party connections, whether systems are hosted internally or outsourced, the number of unsecured connections, the use of wireless access, volume of network devices, end-of-life systems, extent of cloud services, and use of personal devices.

∙Delivery Channels. Various delivery channels for products and services may pose a higher inherent risk depending on the nature of the specific product or service offered. Inherent risk increases as the variety and number of delivery channels increases. This category addresses whether products and services are available through online and mobile delivery channels and the extent of automated teller machine (ATM) operations.

∙Online/Mobile Products and Technology Services. Different products and technology services offered by institutions may pose a higher inherent risk depending on the nature of the specific product or service offered. This category includes various payment services, such as debit and credit cards, person-to-person payments, originating automated clearing house (ACH), retail wire transfers, wholesale payments, merchant remote deposit capture, treasury services and clients and trust services, global remittances, correspondent banking, and merchant acquiring activities. This category also includes consideration of whether the institution provides technology services to other organizations.

∙Organizational Characteristics. This category considers organizational characteristics, such as mergers and acquisitions, number of direct employees and cybersecurity contractors, changes in security staffing, the number of users with privileged access, changes in information technology (IT) environment, locations of business presence, and locations of operations and data centers.

∙External Threats. The volume and type of attacks (attempted or successful) affect an institution’s inherent risk exposure. This category considers the volume and sophistication of the attacks targeting the institution.

Risk Levels

Risk Levels incorporate the type, volume, and complexity of the institution’s operations and

threats directed at the institution. Inherent risk does not include mitigating controls.