Overview
The NCUA holds federally insured credit unions to increasing cybersecurity standards, and examination findings in this area carry real consequences — from mandatory remediation plans to supervisory agreements. Whether you're preparing for an upcoming exam, working through a prior finding, or building a stronger program between cycles, we help credit unions develop the documentation, controls, and processes that examiners expect to see.
A credit union came to us after receiving a cybersecurity-related finding in their last exam. The controls existed — they just weren't documented in a way the examiner could evaluate. Good security that can't be demonstrated is still a finding.
Examination Readiness
We review your cybersecurity program against NCUA examination procedures and the FFIEC Cybersecurity Assessment Tool (CAT), identifying gaps before the examiner does and helping you build a credible, documented response to each area of focus.
Control Assessment
We assess your security controls across access management, incident response, vendor oversight, and business continuity — the areas NCUA examiners consistently focus on — and give you a clear picture of current maturity and where gaps remain.
Member Data Protection
We review your technical and operational controls for protecting member data, including third-party vendor relationships and how sensitive data flows in and out of your environment. Vendor oversight is a consistent area of examiner attention.
NCUA examiners increasingly use the FFIEC CAT as a baseline. If your credit union hasn't mapped your program to that tool, you're going into an exam without knowing the score.
What You Can Expect
- Gap assessment against NCUA examination expectations and the FFIEC CAT
- Review of incident response, access management, and vendor oversight controls
- Documentation review and remediation guidance aligned to examiner expectations
- Support developing or updating your Information Security Program
- Board-ready reporting suitable for supervisory committee presentation
Vendor oversight gaps? Our Vendor Cybersecurity Reviews service addresses third-party risk in a structured, repeatable way that satisfies examiner expectations.
Who This Is For
- Federally insured credit unions preparing for an upcoming NCUA examination cycle
- Credit unions that received a cybersecurity-related finding in a prior exam and need to document corrective action
- Credit union leadership and supervisory committees that need board-ready reporting on their current cybersecurity posture
- Organizations building or updating their Information Security Program to meet NCUA examiner expectations
- Credit unions that have added new technology, vendors, or digital banking capabilities and want to assess the security implications before their next exam
Common Questions
What does an NCUA cybersecurity examination typically focus on?
NCUA cybersecurity examinations assess whether a credit union's information security program is adequately designed and operating effectively. Examiners consistently focus on: governance and board oversight of the security program, risk assessment processes, access controls and identity management, incident response preparedness, vendor and third-party risk management, and business continuity planning. Documentation quality matters — examiners evaluate whether your program is written down, current, and actually followed, not just whether controls exist in practice.
What is the FFIEC Cybersecurity Assessment Tool (CAT)?
The FFIEC Cybersecurity Assessment Tool is a framework developed by the Federal Financial Institutions Examination Council that helps organizations measure cybersecurity preparedness and maturity. It maps inherent risk (based on your institution's profile, size, and technology) against cybersecurity maturity across five domains: Cyber Risk Management and Oversight, Threat Intelligence and Collaboration, Cybersecurity Controls, External Dependency Management, and Cyber Incident Management and Resilience. NCUA examiners use the CAT as a reference when evaluating credit union cybersecurity programs. If your program hasn't been mapped to it, you're entering an exam without knowing the baseline the examiner is working from.
What are the most common NCUA cybersecurity findings?
The most frequently cited NCUA cybersecurity findings involve: inadequate or undocumented risk assessments, insufficient vendor oversight and third-party risk management, weak access controls (particularly for privileged accounts and remote access), incomplete or untested incident response plans, and insufficient board-level reporting on cybersecurity matters. Many of these findings stem not from the absence of controls, but from inadequate documentation — controls that exist in practice but cannot be demonstrated to an examiner's satisfaction.