Why You Need Both an Information Security Risk Assessment and a Framework Self-Assessment

When it comes to managing cybersecurity risk in community financial institutions, there’s often confusion between two key activities: the Information Security Risk Assessment and a framework-based self-assessment (like the NIST Cybersecurity Framework (CSF) or the Cyber Risk Institute (CRI) Profile).

While they may sound similar and even overlap in certain areas, they serve very different purposes. If your institution is only completing one, you could be leaving gaps in your security posture, compliance obligations, or even your board reporting.

Let’s break down the differences and why both are essential.

An Information Security Risk Assessment (ISRA) is a risk-based analysis of your systems, data, and operations. The purpose? To identify actual threats and vulnerabilities that could impact your institution and determine how likely and how severe those risks might be.

It typically includes:

• A breakdown of critical systems and assets (think online banking, ACH, core systems)
• Threats that could impact those assets (cyberattacks, insider threats, third-party failures)
• Vulnerabilities or control gaps
• A calculation of risk (likelihood × impact)
• Decisions on how to reduce, transfer, or accept that risk

This assessment is all about context. It’s specific to your institution, your environment, and your tolerance for risk. And it’s required under GLBA and FFIEC guidance.

What is a Cybersecurity Framework Self-Assessment?

A cybersecurity self-assessment, like the CAT Tool, NIST CSF 2.0, or the CRI Profile, helps you measure how mature and complete your security program is, regardless of specific threats. These frameworks are designed to promote best practices across functions like:

• Asset management
• Access control
• Incident response
• Third-party oversight
• Business continuity

The goal of a self-assessment is to evaluate how well your institution has implemented these controls, and to help you identify opportunities for improvement.

This is a standards-based evaluation, not a risk-based one. It helps ensure that your cybersecurity program aligns with recognized industry expectations and gives you a consistent structure for communicating maturity to your board or examiners.

Key Differences: Risk vs. Maturity

Think of it this way:

• A risk assessment helps you understand what’s most likely to go wrong, and what to do about it.
• A framework assessment helps you understand how well you’ve built your security program and where it may need strengthening.

Why Both Matter

Completing one without the other can give you a false sense of security. You might have strong policies and controls in place, but if they don’t address your most pressing risks, you may still be vulnerable. Likewise, even the most detailed risk assessment won’t help much if you don’t have the internal structure or maturity to act on the findings.

Both assessments serve different, but complementary, purposes:

• The risk assessment tells you what to focus on.
• The self-assessment tells you how well you're executing.

Together, they provide a well-rounded, defensible view of your cybersecurity posture, something your board, auditors, and regulators will expect more of in today’s threat environment.

Need help getting started?

At Bedel Security, we help community banks and credit unions navigate both the risk-based and framework-based sides of cybersecurity. If you're not sure where you stand or what examiners will expect, reach out to our team. We make it make sense.