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Financial Services Law Insights and Observations

FFIEC Releases FAQs on Cybersecurity Assessment Tool

Federal Issues FFIEC Bank Supervision NIST Risk Management Privacy/Cyber Risk & Data Security

Federal Issues

On October 17, the FFIEC published a Frequently Asked Questions guide related to the Cybersecurity Assessment Tool (Assessment) that was released in Summer 2015. Developed to assist financial institutions identify risks and to assess cybersecurity preparedness, use of the Assessment is voluntary. The FAQs guide explains that management may use the Assessment to determine an institution’s cybersecurity maturity level within five different domains: (i) Cybersecurity Risk Management and Oversight; (ii) Threat Intelligence and Collaboration; (iii) Cybersecurity Controls; (iv) External Dependency Management; and (v) Cyber Incident Management and Resilience. The FAQs guide clarifies that “the Assessment is not designed to identify an overall cybersecurity maturity level.” Regarding third-party oversight, FAQ number 10 explains that the Assessment may be used as a resource for management’s “oversight of third parties as part of the institution’s comprehensive third-party management program.” Additional topics addressed in the FAQs include, but are not limited to, the following: (i) how the Assessment aligns with the National Institute of Standards and Technology Cybersecurity Framework; (ii) whether an automated version of the Assessment will be released; (iii) the Assessment’s ability to determine an institution’s Inherent Risk Profile; and (iv) the expectations for Inherent Risk Profile levels to align with an institution’s Cybersecurity Maturity.

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