No More CAT Naps: It’s Time to Upgrade Your Cyber Strategy?
The Federal Financial Institutions Examination Council Cybersecurity Assessment Tool (FFIEC CAT) sunsets on August 31, 2025, but does that mean you scan skip finding a replacement? Not so fast my friend. While the CAT was always voluntary, its retirement doesn’t signal the end of cybersecurity expectations from regulators. In fact, it raises the stakes. Financial institutions must still identify risks, mature their programs, and defend against increasingly complex cyber threats. So, the real question isn’t if you need a replacement, it’s what you should replace it with. This blog breaks it down.
Time to Wake Up The CAT
Since 2015, the cybersecurity landscape has evolved but the FFIEC CAT has been caught napping while key threats emerged and intensified:
Supply Chain Risks: Emerging threats like fourth party and cybersecurity supply chain threats are not adequately addressed by the CAT.
Governance Gaps: Many institutions still lack trained leadership to oversee cybersecurity governance, and the CAT offers little support here.
System Breaches: A steady drumbeat of breaches proves that stronger incident response planning is no longer optional.
With today’s evolving threat environment and heightened regulatory expectations, relying on the CAT is like using a flip phone in a smartphone world. It’s time to trade it in for a framework that’s built for modern cybersecurity.
So, which framework is the best fit for your institution?
Time for Something Better
As the CAT phases out, these frameworks have emerged as the most viable and widely adopted alternatives:
One Framework to Rule Them All? Not Quite.
| Aspect | NIST CSF 2.0 | CRI Profile 2.1 | CIS Controls 8.1 | CISA CPGs | FFIEC CAT |
|---|---|---|---|---|---|
| Scope | Broad, industry agnostic | Financial sector specific | Broad, technical focus | Critical infrastructure, SMEs | Financial sector specific |
| Core Structure | 6 functions (Govern, Identify, Protect, etc.) | NIST CSF based, 4 impact tiers | 18 controls, 3 implementation groups | 38 goals aligned with NIST CSF (no Govern) | 5 domains, 2 components (maturity, risk) |
| Total Controls / Statements | 106 subcategories (across 6 functions) | 208 diagnostic statements, 4 tiers | 153 safeguards (across 18 controls) | 38 goals | 494 declarative statements |
| Target Audience | All industries, mature organizations | Financial services (bank, credit union, fintech) | All industries, SMEs to enterprises | Critical infrastructure, SMEs | Financial institutions (banks, credit unions) |
| Implementation | Flexible, risk based, strategic | Streamlined, prescriptive, risk focused | Prescriptive, prioritized, actionable | Simplified, measurable, voluntary | Structured, assessment based, regulatory focused |
| Maturity Model | 4 tiers (partial to adaptive) | 4 tiers (based on systemic impact) | 3 implementation groups (IG1, IG2, IG3) | None (baseline goals) | 5 maturity levels (baseline to innovative) |
| Control Mapping | CIS Controls, ISO 27001, NIST 800‑53, CRI Profile, FFIEC CAT | CIS Controls, NIST CSF, FFIEC CAT, NIST 800‑53 | NIST CSF, NIST 800‑53, ISO 27001, PCI DSS; partial to CIS controls | NIST CSF, NIST 800‑53, ISO 27001; partial to CIS controls | NIST CSF, NIST 800‑53, CRI Profile; partial to CIS controls |
| Complexity | High, requires expertise | Moderate, Excel based tool | Low to moderate, actionable guidance | Low, beginner friendly | Moderate to high, regulatory driven |
| Regulatory Alignment | High (complex implementation) | Strong (financial regulations, FFIEC) | Moderate (PCI DSS, HIPAA, GDPR) | Moderate (NIST CSF, critical infrastructure) | Strong (FFIEC, GLBA, financial regulations) |
| Strengths | Comprehensive, flexible, global standard | Financial focus, risk assessment | Practical, prioritized, SME friendly | Accessible, high impact, critical infrastructure focus | Regulatory alignment, detailed for financial sector |
| Weaknesses | Complex, resource intensive | Limited to financial sector | Less strategic, technical focus | Limited scope, lacks governance | Complex, being phased out Aug 2025 |
Upgrade Your CAT to a Lion: Choose a Framework That Roars
While the CAT is sleeping your cybersecurity program cannot afford to. Today’s threats demand more than a checklist. Choose a framework that fits your institution and roars with strength, strategy, and regulatory alignment:
NIST CSF 2.0: Ideal for larger institutions with mature cybersecurity programs, offering flexibility and robust governance. Its alignment with the CAT’s foundation makes it a seamless transition, but it requires significant expertise to implement and manage.
CRI Profile 2.1: Best for financial institutions, especially smaller institutions, due to its sector-specific focus and streamlined approach. With fewer statements than the CAT, it’s easier to implement while maintaining regulatory alignment.
CIS Controls 8.1: Suited for institutions needing actionable, technical controls. It’s less comprehensive than NIST CSF but highly practical for immediate improvements and favored by IT professionals.
CISA CPGs: Perfect for small organizations or those new to cybersecurity, providing a simple, high-impact baseline. However, it lacks governance and may require supplementation.
Many institutions may benefit from a hybrid approach. For example, use CRI Profile 2.1 for financial sector compliance and layer in CIS Hardened Images for technical control validation.
Ready to Upgrade your CAT to a Lion? Let’s Roar Together.
The sun is setting on the FFIEC CAT, but your cybersecurity program should be rising to meet today’s challenges. Whether you’re a small credit union or a large regional bank, CyberAssurance can help you select, implement, and optimize the framework that fits your institution—and your future.
Partner with a cybersecurity consulting firm that understands your industry’s unique compliance requirements and risk landscape. Whether you need an ITGC review, vendor risk management best practices, ransomware readiness assessment, or cybersecurity training program, CyberAssurance provides expert guidance and actionable recommendations.
Experience the CyberAssurance difference. How can we help? Contact us today to learn more.
