Moving from the CAT to CSF: A More Strategic Path for Community Financial Institutions

The FFIEC Cybersecurity Assessment Tool (CAT) officially sunset on August 31, 2025. That means institutions that just completed it one last time still have a little breathing room, but not much. It’s time to start planning what comes next. At Bedel Security, we’ve been helping community banks and credit unions make that transition to the NIST Cybersecurity Framework (CSF).

Why the CAT Worked, and Where It Fell Short

The CAT had its strengths. It was detailed, familiar, and easy to follow. With more than 600 statements and simple “yes” or “no” answers, it gave institutions a clear way to check their progress.

But that same structure became its downfall. Because it was so detailed, it quickly became outdated as technology changed. It forced people into the weeds, focusing on small, tactical things instead of the big picture.

And if we’re honest, a lot of banks stretched some of those “yes” answers a bit too far just to keep the report looking good.

Over time, the CAT turned into a compliance exercise instead of a real look at cybersecurity maturity.

The Strength of the NIST CSF: Concise and Strategic

By comparison, the NIST CSF is lean and flexible. It has just over 100 statements (108 in version 2.0) across six core functions: Govern, Identify, Protect, Detect, Respond, and Recover.

That conciseness is a huge advantage. You can see the big picture—where you stand, where you’re strong, and where you need to improve—without having to wade through hundreds of questions.

I’ve had some folks in the industry push back, saying it’s too vague or not actionable enough. I disagree. The CSF isn’t meant to tell you exactly what to do; it’s meant to help you build a roadmap for how your institution will mature over time.

Using the CSF to Measure and Set Strategy

At Bedel Security, we’ve paired the CSF with its implementation tiers, or maturity levels. Instead of checking yes or no, we assess how developed each area is: none, ad hoc, defined, repeatable, or optimized.

When you use Tier 3 (Repeatable) as your benchmark, you can compare where your program stands today against that target level in each of the 6 core functions. That comparison highlights your specific gaps and shows you where you need more attention to reach a consistent, sustainable level of maturity.

Those insights feed directly into your cybersecurity strategy. They help you decide where to invest resources, what to prioritize, and how to communicate progress to leadership and the board.

The CSF becomes more than an assessment; it becomes the foundation for your cybersecurity strategic plan.

When You Need More Detail

The CSF isn’t meant to replace the technical side of cybersecurity nor is it meant to be a deep-dive risk assessment. If you’re looking for detailed control implementation, specific configurations, or device-level requirements, that’s where your policies, standards, and asset-based risk assessment come in.

Those tools dig into the “how.”

The CSF defines the “what” and the “why.”

They work best when they work together.

Setting the Goal: Aim for “Repeatable”

For most community banks and credit unions, the realistic goal should be Tier 3 (Repeatable). That’s where cybersecurity practices are defined, consistent, and part of day-to-day operations. Once you reach that level, your program has rhythm and structure, and your strategy shifts from reactive to proactive.

Generally, we find that organizations at this level are able to handle a changing technological landscape and the threats that go along with it.

Conclusion: From Compliance to Clarity

The CAT had its place. It helped the industry get started. But today, we need something that helps us think strategically, not just check boxes.

With about 100 focused statements, the NIST CSF gives community banks and credit unions a clear, practical way to measure maturity, benchmark against Tier 3, and set a focused strategy for improvement.

It’s not about doing more work; it’s about doing the right work and building a security program that grows with your bank.

If you’re looking for help completing your CSF assessment, we’re offering this as a service to financial institutions. We’d be happy to help you get started and guide your transition from the CAT to the CSF. Check it out here!