After nearly a decade, the FFIEC is officially sunsetting its Cybersecurity Assessment Tool (CAT) on August 31, 2025. This decision signals more than the end of a tool—it represents a critical shift toward risk-informed cybersecurity governance, aligning security priorities with today’s rapidly evolving threat landscape and regulatory expectations.
Why the Shift?
Over the years, the CAT became less a driver of security progress and more a compliance-oriented artifact. Its design—with structured maturity levels and predefined domains—was highly prescriptive, encouraging institutions to focus on meeting criteria rather than addressing evolving threats. The diagnostic questions, often subjective and rigid, led many institutions to interpret cyber governance as a matter of formality: check the box, score the assessment, move on.
While the CAT enabled organizations to look at cybersecurity more holistically, the result was a culture of “compliance theater”—strategies crafted not to improve security but to pass examinations. Rather than prioritizing risk impact or alignment with the business, teams often pursued maturity levels as badges of success. This mindset focused on regulatory ‘fire drills’, delaying proactive measures to adapt to novel threats like AI-enabled fraud or supply chain infiltration.
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Changing the Mindset: From Compliance to Continuous Risk Management
The sunsetting of CAT is a loud and clear message: financial institutions must now make the leap from a static maturity model to dynamic cyber governance rooted in real-world risk. This demands a deep reimagining of how cybersecurity is approached—from the boardroom to the server room:
- Mindset Transformation: Security is no longer about passing audits – it’s about business-aligned risk decisions.
- Cyber Risk Accountability: Cybersecurity governance must break out of compliance silos and become a cross-functional enterprise discipline.
- Cultural Shift: Boards and executives need to engage beyond attestation, asking how cyber risks can cause harm to the organization and to those outside of the organization.
We’ve long known that compliance does not equal security – this evolution reinforces that compliance does not equal effective risk management.
What Comes Next?
With CAT’s retirement, the FFIEC encourages institutions to transition to more adaptive, structured, and risk-responsive frameworks such as the Cyber Risk Institute (CRI) Profile and the Center for Internet Security Critical Security Controls.
CRI Profile delivers a financial-sector-specific roadmap, consolidating over 2,500 regulatory expectations into a streamlined assessment.
CIS Controls, a prescriptive, prioritized, and simplified set of best practices that strengthen an organization’s cybersecurity posture.
Both frameworks support what CAT could not: a transition to security decisions based on impact, not formality.
With the retirement of the FFIEC CAT, financial institutions have an opportunity to move beyond checkbox compliance and adopt cybersecurity governance rooted in accountability, impact, and real-world risk. Maturity badges or being in top quartile with peers is no longer the right measuring stick. This is a shift from asking “Are we compliant?” to “Are our controls reasonable and at an acceptable level of risk to all parties.”
Rethinking Cyber Governance: A Smarter, Unified Approach
Cyber governance today should operate like an integrated system—connecting strategy, compliance, risk, and technology to work as one. Leveraging the Duty of Care Risk Analysis Standard “DoCRA” integrated into GRC platforms like Reasonable Risk, organizations can identify risks to all potential claimants and document evidence of reasonableness. This governance capability aligns business and cyber risk management. This shifts cybersecurity from a tech concern to a business driver.
Why Retiring CAT Is Progress
Retiring CAT isn’t a downgrade—it’s an upgrade in thinking and encourages security teams to meet the needs of today’s technology and threat landscape. Financial institutions must take this opportunity to:
- Build governance models based on actual risks
- Align cybersecurity decisions with business impact and legal responsibility
- Deliver clear, defensible assessments that resonate with both examiners and executives
- Demonstrate that controls are reasonable and the risk is acceptable to all interested parties
The Stakes Are Rising
Cyber threats are growing more complex and dangerous. Major incidents like the SWIFT heist, Fiserv/MOVEit, and Equifax breach exposed serious gaps in old approaches. Today’s attackers use smarter, faster, AI-driven tactics. FS-ISAC’s latest report warns of rising fraud, third-party risks, and social engineering powered by generative AI. Institutions must evolve—or face greater consequences.
Cybersecurity isn’t just about defending systems, it’s about making defensible decisions that consider all impacts including the business, shareholders, customers, business partners, and any potential claimant.
Compliance Pressure Is Mounting – and It’s Personal
Regulators are intensifying scrutiny, enforcement actions are escalating, and the financial stakes have never been higher.
Key Mandates Reshaping Governance:
- SEC Incident Disclosure Rule (2023): Requires board and executives to take direct responsibility for cybersecurity oversight.
- SEC Regulation S-P Amendments (2024): Stronger board and executive oversight of data safeguarding, disposal practices and third-party oversight by end of 2025.
- DORA (EU, 2022): Requires financial entities to adopt a unified, risk-based approach to ICT (Information Communication Technology) resilience.
- EU NIS 2 (2024): Essential financial entities have heighted obligations including mandatory framework adoption, frequent risk assessment, stringent incident reporting, rigorous oversight of 3rd parties.
Cyber rules are the new (SOX) Sarbanes-Oxley, executives and boards can face personal accountability, heavy fines, and litigation risks, even losing their jobs, for failing to govern cybersecurity effectively.
Operationalizing Cyber Risk Governance Through DoCRA
In today’s digital-first financial landscape, Cyber Risk Governance must evolve into a strategic command center—one that seamlessly connects risk, compliance, finance, technology, and business strategy. At the heart of this transformation is Duty of Care Risk Analysis (DoCRA), a framework that translates technical risks into business impacts that can be consumed by any executive or interested party.
DoCRA empowers institutions to navigate uncertainty with clarity, ensuring governance is transparent to examiners and aligned with regulatory mandates like the SEC Cybersecurity Rule (July 26, 2023).
Cyber Risk Governance today must move beyond checklists and maturity scores. To be defensible, organizations must:
- Consider foreseeable harm—to internal teams, customers, partners, and the broader ecosystem.
- Document the nature and impact of risks—with transparency and relevance to actual stakeholders.
- Embrace Duty of Care Risk Analysis (DoCRA) – demonstrate that controls are not only present but reasonable under the circumstances.
By adopting DoCRA, institutions gain a living governance system—one that adapts to threats, supports budget decisions, and withstands legal and regulatory review.
Conclusion
The retirement of the FFIEC CAT marks a pivotal moment in cybersecurity oversight. Financial institutions must now shift from static maturity models to continuous, risk-informed assessments that reflect today’s dynamic threat landscape and regulatory demands.
Good cyber governance is not a checklist; it’s a business capability. Financial institutions have an opportunity to manage cyber risks just like any other part of the business. By adopting Duty of Care Risk Analysis-based frameworks, institutions can build governance models that are:
- Transparent and understandable to regulators, executives, and stakeholders.
- Centered on foreseeable harm—weighing the impact on internal and external parties.
- Proportional and reasonable showing that controls are appropriate and not excessive or negligent.
- Aligned with business strategy—balancing risk reduction with operational goals.
- Defensible – documenting a risk program that regulators commonly define as “reasonable.”
Institutions that delay modernization face the risk of:
- Regulatory penalties
- Civil liability and punitive damages
- Reputational damage
- Operational disruption
Act now and modernize your cyber risk management by:
- Selecting a Suitable Framework
- Selecting the CRI Profile for regulatory alignment and detailed compliance guidance.
- Enhancing Legal Defensibility Conduct your required risk analysis using Duty of Care Risk Analysis (www.docra.org) to align cybersecurity decisions with legal due care.¹
- Strengthening GRC Tooling & Integration Improve Governance, Risk, Compliance (GRC) processes
- Requesting Expert Support Contact Reasonable Risk for Cyber Risk Advisory services.
With the sunset of FFIEC CAT, the CAT is out of the bag – financial institutions must move beyond checkbox compliance. Tools like CRI Profile and CIS RAM support this transition with risk assessments focusing on harm, reasonable and legal defensibility. Reasonable Risk SaaS automates risk management using DoCRA and provides easy executive reporting.
¹ For DoCRA’s defensibility against negligence claims, see CIS RAM at cisecurity.org, and “Commentary on a Reasonable Security Test.”
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