This article was updated on August 28, 2019. See below for the updates.
What is the FSSCC Cybersecurity Profile?
The FSSCC Cybersecurity Profile was published on October 25, 2018 by the Financial Services Sector Coordinating Council (FSSCC). The FSSCC is a private entity comprised of 70 members from financial services organizations. Their cybersecurity profile has multiple tiers, which allow users to answer a scalable set of questions. This scaling is designed to provide an expedited assessment of the user's organization's cybersecurity preparedness.
The FSSCC has publicized their Cybersecurity Profile as a resource, designed to simplify the regulatory burden placed on financial institutions. According to the FSSCC's Benefits to Financial Institutions section of their website, the tool offers a "73% reduction for community institution assessment questions" when compared to the FFIEC CAT.
In addition to the tool's claims of efficiency, the tool's development is largely credited to organizations familiar to the financial services industry. The Press Release includes names such as the American Bankers Association, Bank Policy Institute, the Institute of International Bankers, and more.
Beyond this, the FSSCC has made multiple appeals to the Cybersecurity Profile's usefulness in regulatory examinations, going so far as to claim, "The numerous and substantial benefits [of using the FSSCC Cybersecurity Profile] to the financial services sector are: […] Supports tailored supervision, examinations, and collaboration among state, federal, and international supervisors," per the FSSCC Overview and Users Guide.
What is the FFIEC Cybersecurity Assessment Tool?
The FFIEC Cybersecurity Assessment Tool (CAT) was initially published on June 30, 2015, and updated May 31, 2017. The CAT was designed by the Federal Financial Institutions Examination Council (FFIEC), a formal interagency body, comprised of members from the FRB, FDIC, NCUA, OCC, CFPB, and SLC. The CAT is standardized, which allows users to answer a specific set of questions, designed to provide a thorough assessment of their organization's cybersecurity preparedness.
The FFIEC CAT includes 494 cybersecurity maturity statements, which has resulted in some complaints. However, it is not only designed to provide a detailed assessment of a financial institution's current state of cybersecurity preparedness, it also enables targeted and long-term planning for growth and improvement.
With regard to examinations:
• The FDIC continues to heavily rely on the InTREx Work Program. While InTREx does state financial institutions are not required to use the FFIEC CAT to assess cybersecurity preparedness, the program also states FDIC examiners will reference the CAT's Appendix A when performing examinations.
• The NCUA is currently implementing the Automated Cybersecurity Examination Tool (ACET). The ACET is based on the FFIEC CAT, with a document request list to help credit unions understand, gather, and organize the documents needed for the examination. Read our blog on FAQs about the ACET.
• In their Spring 2018 Semiannual Risk Perspective, the OCC announced they had "implemented the Federal Financial Institutions Examination Council (FFIEC) Cybersecurity Assessment Tool (CAT) into its examination process." In addition, an OCC representative at the 2019 CoNetrix KEYS Conference Examiner Panel indicated the OCC is piloting their own segmented version of the FFIEC CAT, to be fully completed on a three-year cycle.
August 2019 Update: In July 2019, the OCC replied to a comment from the FSSCC in the Federal Register. The FSSCC asked the agencies to "make a clear statement that other methodologies, such as NIST Cybersecurity Framework and the FSSCC Cybersecurity Profile, are acceptable inputs into the examination process." The OCC replied that financial institutions "may choose to use the [FFIEC CAT], the NIST Cybersecurity Framework, or any other risk assessment process or tool to assess cybersecurity risk."
• The FRB's supervisory letter about the tool, SR 15-9, indicated the CAT's planned use in examinations, and the FRB was a contributor in the May 2017 update of the tool, per their 2017 Annual Report. Additionally, a list of Information Technology Guidance was published, including the FFIEC CAT as a "Policy Letter."
Will the FSSCC Cybersecurity Profile Replace the FFIEC Cybersecurity Assessment Tool?
While the FSSCC Cybersecurity profile has fewer questions, and the FSSCC has expressed interest in seeing the tool used during regulatory examinations, the federal banking agencies have not yet expressed the same interest.
In addition, while completing the FFIEC CAT is not required, four years into the CAT's implementation, examiners are now familiar with the tool and the agencies continue to supplement and reference the CAT in their own examination programs. In light of this, using the CAT to assess cybersecurity preparedness could help expedite the examination process, as the tool may be used during an exam.
At this point in time, it is not clear what the future holds for the FSSCC Cybersecurity Profile. Due to the thorough nature and widespread adoption of the FFIEC CAT, it is difficult to imagine the CAT will be replaced by any tool in the foreseeable future.
August 2019 Update: In August 2019, the FFIEC published a press release encouraging a standardized approach to assessing cybersecurity preparedness. While the press release lists the FFIEC CAT, NIST Cybersecurity Profile, Center for Internet Security Controls, and FSSCC Cybersecurity Profile as references to "support institutions in their self-assessment activities," the press release reiterates that "the FFIEC does not endorse any particular tool" and the "tools are not examination programs."
Does CoNetrix have anything that can help with assessing cybersecurity preparedness?
Yes. The Tandem Cybersecurity module took the FFIEC CAT PDF content and streamlined it into an easy-to-use web-based application. With email reminders, charts and graphs, presentation documents, optional peer comparison, and tools for the NCUA's ACET, you can put the FFIEC CAT to work for you. Get started for free with Tandem Cybersecurity.