After the August 31st sunset of the FFIEC CAT, community banks have either started to transition away or are confirming their plan and evaluating frameworks such as the Cyber Risk Institute (CRI) Profile, NIST Cybersecurity Framework (CSF 2.0), or CIS Controls. Each of these frameworks provides structure and credibility, but for many community banks, one essential element is missing: a clear, measurable view of inherent risk.
While the CRI Profile framework meets regulatory expectations, the impact tiering was designed with large, complex institutions in mind. For community banks, this creates a critical gap. Without measurable inherent risk, management teams and boards lose visibility into what drives exposure, how risk compares across risk categories, and what controls have the biggest impact on reducing risk.
That’s where the Finosec Cybersecurity Assessment Tool (Finosec CAT) comes in. Developed in partnership with the Independent Community Bankers of America (ICBA), it was built from the ground up for community banks seeking a right-sized alternative to enterprise-tiered frameworks.
The Core Difference: Measurable Inherent Risk That Fits Community Banks
The Finosec CAT preserves the inherent risk profile structure that community bankers already know from the FFIEC CAT while addressing its biggest limitation, the lack of updates since 2017. With the Finosec CAT the inherent risk profile has been updated to reflect today’s reality: integrating new threats such as AI, APIs, real-time payments, and cloud dependencies. This modernized inherent risk profile builds directly upon the data from the FFIEC CAT, and with Finosec’s Information Security Assistant, Regi Ranger, previous Inherent Risk Profile results are imported, preserving institutional history and minimizing effort by having 75% of the Inherent Risk Profile answers from the previous year.
In short, Finosec CAT enables banks to continue the CAT process they’ve already mastered, but with better data, automation, and inherent risk measurability.
Why CRI Is Not Right-Sized For Community Banks
The Cyber Risk Institute (CRI) Profile Impact Tiers categorize institutions based on size and systemic importance, which makes sense for a $40 billion+ institutions with complex risk exposure.
But for a $400 million community bank serving their local customers, this approach can feel misaligned.
CRI’s tiers are determined by enterprise characteristics, not the actual risk associated with a community bank’s services, delivery channels, or technology footprint, lumping all institutions with less than 1 Million Customers, < 1% of the country’s financial transactions, into one impact tier, tier 4.
Finosec CAT takes a fundamentally different path. It was built for practicality and proportionality, empowering community banks to assess their cybersecurity posture through a lens that reflects how they actually operate, not how mega banks do.
Understanding the Inherent Risk Gap
Many institutions transitioning from the FFIEC CAT to NIST, CIS, or CRI frameworks don’t realize what they may be losing: the inherent risk profile that made the original CAT such a valuable governance tool. Inherent risk quantifies the “what could go wrong” before controls are considered, allowing boards to understand the baseline exposure that drives cybersecurity investment and oversight.
Without inherent risk, institutions can easily fall into two traps:
- Misaligned Maturity: Teams implement controls without understanding whether they are proportional to their true risk.
- Reporting Blind Spots: Boards see control maturity but lack the context to interpret them against the institution’s unique risk profile.
Finosec CAT fills that void by modernizing inherent risk profile measurement. Each risk factor is presented in a least-to-most scale that executives and regulators already understand, connecting inherent risk directly to control maturity and residual risk. The result: right-sized risk management for community institutions.
A Familiar Process, Modernized for Today’s Threats
The Finosec CAT doesn’t reinvent the wheel, it refines it.
Our tool retains the familiar structure of the FFIEC CAT, including the five inherent risk domains:
- Delivery Channels
- Online/Mobile Products and Technology Services
- External Threats
- Organizational Characteristics
- Connection Types
To this, Finosec adds a sixth category: Emerging Technologies, to account for today’s evolving banking technology. Institutions can now assess risks related to expanding risks like:
- Artificial Intelligence and machine learning
- API-driven integrations and open banking
- Cloud dependency and shared-service exposure
- Real-time payment adoption and FedNow readiness
These updates ensure that your inherent risk profile reflects the world you operate in today, not the one that existed a decade ago.
Why Inherent Risk Still Matters, Even If You’ve Already Chosen a Framework
If your institution has already chosen NIST CSF 2.0, CIS Controls, or even the CRI Profile, these frameworks are strong foundations. But each lacks one crucial component: a measurable, contextual inherent risk model that scales for community banks.
Here’s why that matters:
- Executive and Board communication: Inherent risk provides the benchmark that helps boards understand if control maturity is sufficient or overextended.
- Strategic prioritization: Defining the institution’s inherent risk profile allows limited resources to be directed where they will have the most impact.
Finosec CAT enhances whichever framework you already use by introducing measurable inherent risk as the context that connects maturity to reality. Whether you align to NIST, CIS, or CRI, Finosec CAT acts as the translation layer between your technical controls and your strategic oversight.
Designed for Community Banks, Built in Partnership with the ICBA
Community banks face unique cybersecurity realities: small teams, limited budgets, and an outsized regulatory burden. Recognizing this, Finosec built its platform in partnership with the ICBA to ensure that it reflects the governance, staffing, and technology conditions specific to community institutions. The platform automates the heavy lifting of things like data import, control mapping, and reporting, so institutions can focus on managing risk rather than relying on manual labor-intensive processes.
This is what right-sized cybersecurity governance looks like: simplified, standardized, and designed for the community banking model.
Bridging the Gap Between Frameworks and Action
Finosec CAT is more than a replacement for the FFIEC CAT, it’s the bridge between frameworks and practical governance. Whether your institution chose NIST, CIS, or CRI, the tool adds measurable context that enhances whatever structure you already have.
- For CRI Users: It replaces impact tiering with measurable inherent risk, giving your institution clarity without enterprise complexity.
- For NIST Users: Finosec CAT overlays inherent risk scoring and executive reporting, maintaining the familiar executive reporting format.
- For CIS Users: It streamlines the implementation of CIS controls and introduces inherent risk quantification that CIS alone doesn’t provide.
In every scenario, Finosec CAT delivers a consistent view of cybersecurity maturity, risk, and readiness that can be easily communicated to examiners and boards alike.
The Continuity Factor: Keeping the Best of the FFIEC CAT
One of Finosec CAT’s greatest strengths is continuity. Through Regi Ranger, your historical FFIEC CAT data can be imported directly, preserving the context and progress your institution has already established. This continuity:
- Eliminates the need to rebuild documentation from scratch
- Maintains your trend data across assessment cycles
- Simplifies executive discussions by showing clear lineage from prior years
Nearly 50% of FFIEC CAT content maps directly into Finosec’s updated model, meaning you’re not starting over, you’re moving forward.
From Complexity to Clarity: Executive Reporting That Drives Decisions
Inherent risk doesn’t just inform compliance, it drives governance. Finosec CAT transforms assessment data into clear, visual reporting that boards can understand at a glance. Each domain’s inherent risk is plotted against control maturity, creating a direct link between exposure and readiness.
Executives can see:
- How current maturity aligns to the bank’s inherent risk profile
- What specific gaps exist between current and target states
- Where risk is increasing or decreasing over time
This structured, repeatable reporting turns cybersecurity from a compliance exercise into a strategic conversation.
Bottom Line: Inherent Risk is the Foundation of Cyber Resilience
As the FFIEC CAT sunsets, community banks face a defining moment. Moving forward without an inherent risk model leaves a blind spot in governance, one that frameworks alone cannot fill. Inherent risk is not an optional component; it’s the foundation of every meaningful cybersecurity program.
The Finosec Cybersecurity Assessment Tool, developed in partnership with the ICBA, delivers what community banks truly need:
- A measurable, contextual, and comparable inherent risk model
- Streamlined controls and continuity from the FFIEC CAT
- Executive-ready reporting and automation tailored for small teams
- A right-sized alternative to enterprise tiering
If your institution has already adopted a new framework, Finosec CAT doesn’t replace it, it enhances it, ensuring that you retain the one element that makes governance meaningful: clarity of inherent risk.
Because when you can measure inherent risk, you can manage it. And that’s what separates compliance from confidence.
Ready to learn more about managing your institution’s inherent risk? Join our upcoming webinar: Why Community Banks Should Keep the Inherent Risk Profile After the FFIEC CAT Sunset
