Community banks and credit unions have relied on the FFIEC Cybersecurity Assessment Tool (CAT) for nearly a decade. That era is ending. The FFIEC CAT sunset is scheduled for August 31, 2025, with agencies directing institutions to use newer government resources like NIST CSF 2.0 and CISA’s Cybersecurity Performance Goals (CPGs) going forward (announcement summarized on the FFIEC site and reflected in the OCC’s 2025 cybersecurity report). FFIECOCC.gov
The shift isn’t just a paperwork exercise. In 2025, U.S. regulators have been sharpening their cyber-supervisory focus across the financial system—highlighting resilience, third-party risk, and exam consistency (see the Federal Reserve’s 2025 Cybersecurity and Financial System Resilience Report).
At the same time, market headlines—like the TransUnion breach that began in July—underscore the stakes of supply-chain and identity risk for banks and their customers.
This post translates the FFIEC CAT sunset into a practical, audit-ready plan for banking executives, CISOs, and IT leaders.
Why the FFIEC CAT is Sunsetting
Regulators determined it’s more effective to align with continuously updated, authoritative frameworks (NIST CSF 2.0) and sector-wide guidance (CISA CPGs) rather than maintain a separate, static tool. The official notice states the CAT will be removed from the FFIEC website on August 31, 2025, with institutions advised to reference NIST CSF 2.0 and CPGs directly.
What that means for banks:
- You’re not “losing” a program—you’re shifting the anchor.
- Expect exam teams to ask how your cyber program maps to NIST CSF 2.0 functions and how you implement CISA CPGs in control priorities.
The 6-Step Transition Plan (90 Days to Confident)
1) Establish your new reference model
Pick NIST CSF 2.0 as your primary framework and adopt the CISA CPGs as a control-prioritization overlay. Document the rationale and approval in InfoSec governance minutes. (Regulatory materials throughout 2024–2025 point institutions toward these resources as the new baseline.)
2) Map CAT→NIST CSF 2.0 (and identify gaps)
- Convert each CAT domain and declarative statement to its closest NIST CSF 2.0 Core function/category/subcategory.
- Flag gaps where CAT had coverage but your program does not—or where NIST CSF 2.0 adds expectations not explicit in CAT (e.g., Supply Chain Risk Management expanded in CSF 2.0).
- Tie each gap to a CISA CPG where applicable to justify prioritization.
3) Update policies, standards, and playbooks
- Align your policy language to CSF 2.0 terminology (Identify, Protect, Detect, Respond, Recover) for consistency with exam expectations.
- Refresh IR playbooks (ransomware, BEC/fraud, third-party compromise) with contact trees and regulator-notification steps that reflect current processes.
- Add third-party risk controls (continuous attack-surface monitoring, software supply-chain assurances) to reflect 2025 threat realities. (Recent incidents—like the TransUnion event that began in July—show how upstream compromises can cascade to banks.)
4) Re-baseline your risk register and control tests
- Re-score risks using a NIST CSF 2.0-aligned methodology.
- Define control objectives per CSF 2.0 subcategories and test procedures aligned to CPGs (e.g., MFA everywhere, phishing-resistant auth, EDR coverage, immutable backups).
- Create a quarterly test calendar that examiners can follow.
5) Update metrics & board reporting
- Replace CAT maturity visuals with a CSF 2.0 heatmap (by function) and a CPG coverage score showing quick wins versus long-lead items.
- Add third-party performance metrics (patch SLAs, SBOM attestations, incident MTTR) and identity risk metrics (number of privileged accounts, phishing-resistant MFA adoption).
6) Prepare your exam narrative (and evidence)
- Draft a concise “Why we moved from CAT to CSF 2.0 + CPGs” memo.
- Assemble a binder (digital folder) with mappings, updated policies, test evidence, risk register, and board decks.
- Cross-reference the Federal Reserve’s 2025 cyber resilience report to show awareness of supervisory themes (consistency across agencies, sector resilience).
What Examiners Will Likely Ask (and How to Answer)
“Show your CAT to CSF 2.0 mapping.”
Provide the matrix and highlight residual gaps with remediation dates.
“How did you prioritize controls?”
Point to CISA CPGs for prioritization logic and your risk heatmap for context.
“Where is your third-party risk program stronger than last year?”
Show vendor tiering, continuous monitoring, SBOM requirements, and tabletop results simulating a credit-bureau/identity-provider outage—highly relevant after July’s third-party breach headlines.
“What changed in board reporting?”
Walk through CSF 2.0 function-level KPIs, incident drill outcomes, and CPG adoption metrics.
Why This Matters Right Now
Regulators’ 2025 publications emphasize sector-wide resilience and supervisory coordination; the OCC’s July 2025 report explicitly references the CAT sunset and points banks to modern frameworks. That same month, the market saw a major third-party breach start that affected a core part of the financial identity ecosystem—another reminder that supply-chain and data-brokering risks are bank risks.
There’s also regulatory motion in open banking/Section 1033: at the end of July, the CFPB moved to stay parts of its open banking rule as it initiates new rulemaking—useful background as you rethink data access, API security, and vendor governance in your CSF 2.0 program.
Quick-Win Control Priorities (CPG-Aligned)
- Phishing-resistant MFA for all privileged and remote access
- EDR + 24/7 monitoring across endpoints and servers
- Immutable, offline backups with routine restore drills
- Email security hardening (DMARC enforcement, advanced BEC rules)
- Vendor-risk controls: continuous external attack-surface monitoring, SBOM/patch SLAs, incident notification clauses
- Rapid incident comms playbook (who calls whom, when, with templates)
- Board-level dashboards aligned to CSF 2.0 and CPGs
Implementation Timeline (Example)
Weeks 1–2: Framework choice memo; CAT→CSF mapping; gap list; board brief.
Weeks 3–6: Policy and playbook updates; vendor-risk uplifts; MFA/EDR coverage checks.
Weeks 7–10: Control testing calendar; drill (BEC or third-party outage); evidence binder.
Weeks 11–12: Finalize dashboards; exam narrative; pre-exam QA.
How Saturn Partners Can Help
The Saturn Partners has helped community banks build audit-ready programs that translate frameworks into measurable controls. If you need a rapid transition from CAT to CSF 2.0—with real-world CPG adoption and third-party safeguards—we’ll bring the playbooks, test procedures, and dashboards to get you over the line before sunset.
Talk to our experts about an FFIEC CAT sunset readiness sprint.