FFIEC CAT CEO Board Overview DRAFT 06_15_15

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 Council 1 (FFIEC) developed the Cybersecurity Assessment Tool
(Assessment) 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 cybersecurityrelated 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:
• 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:
• 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.
• Oversee the performance of ongoing monitoring to remain nimble and agile in addressing
evolving areas of cybersecurity risk.

1

The 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.
2
A mapping is available in Appendix B: Mapping 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. [INSERT HYPERLINK]

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FFIEC Cybersecurity Assessment Tool

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Overview for CEOs and Boards of Directors

Oversee changes to maintain or increase the desired cybersecurity preparedness.

The role of the board, or an appropriate board committee, may include the responsibility to:
• Engage management in establishing the institution’s vision, risk appetite, and overall
strategic direction.
• Approve plans to use the Assessment.
• Review management’s analysis of the Assessment results, inclusive of any reviews or
opinions on the results issued by independent risk management or internal audit functions
regarding those results.
• Review management’s determination of whether the institution’s cybersecurity preparedness
is aligned with its risks.
• Review and approve plans to address any risk management or control weaknesses.
• Review the results of management’s ongoing monitoring of the institution’s exposure to and
preparedness for cyber threats.

Assessment’s Parts and Process
The Assessment consists of two parts: Inherent Risk Profile and Cybersecurity Maturity. Upon
completion of both parts, management can evaluate whether the institution’s inherent risk and
preparedness are aligned.

Inherent Risk Profile
Cybersecurity inherent risk is the level of risk posed to the institution by the following:
• Technologies and Connection Types.
• Delivery Channels.
• Online/Mobile Products and Technology Services.
• Organizational Characteristics.
• External Threats.
Inherent risk incorporates the type, volume, and complexity of the institution’s operations and
threats directed at the institution. Inherent risk does not include mitigating controls. The Inherent
Risk Profile includes descriptions of activities across risk categories with definitions for the least
to most levels of inherent risk. The profile helps management determine exposure to risk that the
institution’s activities, services, and products individually and collectively pose to the institution.
Least
Inherent Risk

Minimal
Inherent Risk

Moderate
Inherent Risk

Significant
Inherent Risk

Most Inherent
Risk

When each of the activities, services, and products are assessed, management can review the
results and determine the institution’s overall inherent risk profile.

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FFIEC Cybersecurity Assessment Tool

Overview for CEOs and Boards of Directors

Cybersecurity Maturity
The Assessment’s second part is Cybersecurity Maturity, designed to help management measure
the institution’s level of risk and corresponding controls. The levels range from baseline to
innovative. Cybersecurity Maturity includes
statements to determine whether an institution’s
Innovative
behaviors, practices, and processes can support
cybersecurity preparedness within the following
Advanced
five domains:
•
•
•
•
•

Cyber Risk Management and Oversight
Threat Intelligence and Collaboration
Cybersecurity Controls
External Dependency Management
Cyber Incident Management and Resilience

Intermediate
Evolving

Baseline

The domains include assessment factors and
contributing components. Within each
component, declarative statements describe
activities supporting the assessment factor at each maturity level. Management determines which
declarative statements best fit the current practices of the institution. All declarative statement 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.
Domain 3:
Cybersecurity
Controls

Domain 4:
External
Dependency
Management

Domain 1: Cyber
Risk Management
& Oversight

Domain 2: Threat
Intelligence &
Collaboration

Domain 5: Cyber
Incident Management
and Resilience

Governance

Threat
Intelligence

Preventative
Controls

Connections

Incident
Resilience
Planning and
Strategy

Risk
Management

Monitoring and
Analyzing

Detective
Controls

Relationship
Management

Detection,
Response and
Mitigation

Resources

Information
Sharing

Corrective
Controls

Escalation and
Reporting

Training and
Culture

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FFIEC Cybersecurity Assessment Tool

Overview for CEOs and Boards of Directors

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).
Risk/Maturity
Relationship

Inherent Risk Levels

Least

Minimal

Moderate

Significant

Most

Cybersecurity
Maturity Level for
Each Domain

Innovative
Advanced
Intermediate
Evolving
Baseline

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.

Supporting Implementation
An essential part of implementing the
Assessment is to validate the institution’s
process and findings and the effectiveness and
sufficiency of the plans to address any
identified weaknesses. The next section
provides some questions to assist management
and the board when using the Assessment.

Assess
maturity and
inherent risk

Reevaluate

Identify gaps
in alignment

Cybersecurity Management &
Oversight
•
•
•

Implement
Determine
What are the potential cyber threats to the
plans to
desired
attain and
state of
institution?
sustain
maturity
maturity
Is the institution a direct target of attacks?
Is the institution’s cybersecurity
preparedness receiving the appropriate level of time and attention from management and the

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FFIEC Cybersecurity Assessment Tool

•
•
•
•
•

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Overview for CEOs and Boards of Directors

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.
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