If you work in a bank or credit union, you already know the expectations have changed. Regulators aren’t just asking whether you have cybersecurity policies; they want to see how effectively your program operates in practice.
With the FDIC, OCC, NCUA, and state examiners increasing their focus on cybersecurity, 2025 exams are expected to be more thorough, technical, and results-driven. Here’s how you can prepare and position your institution for success.
Having documentation is important, but it’s no longer enough. Examiners are asking for evidence that policies are tested, enforced, and embedded into daily operations. Be prepared to show examples like incident response drills, vendor oversight reviews, phishing simulations, and staff cybersecurity training outcomes, not just that these items exist, but that they are functioning as intended.
Showing real-world execution, not just paperwork, will go a long way in satisfying examiner expectations.
Cybersecurity is now considered a governance issue, not just an IT one. Examiners expect the Board and senior management to be regularly briefed on cybersecurity risks, understand the institution’s risk appetite, and take an active role in decision-making.
Regular reporting, documented board discussions, and board-approved cybersecurity strategies or risk assessments can demonstrate that leadership is engaged and accountable.
A common weakness in exams is outdated or generic risk assessments. In 2025, regulators expect assessments to be dynamic, factoring in current threats like ransomware, supply chain attacks, and AI-driven fraud attempts.
Risk assessments should clearly link back to your control environment and risk appetite, showing that your institution makes informed, risk-based security decisions.
Examiners are increasingly asking how institutions validate their incident response capabilities. It’s no longer enough to have a plan sitting on a shelf; regulators want to see that it’s been tested, that lessons learned were documented, and that improvements were made.
Conducting tabletop exercises, testing backup restoration procedures, and rehearsing communication strategies for customers and regulators will all support a stronger showing during an exam.
While protecting systems is important, regulators are placing more emphasis on how quickly and effectively institutions can recover from cyber incidents. Business continuity plans (BCPs), data backup strategies, and tested disaster recovery procedures will be critical areas of focus.
Institutions that can demonstrate an ability to continue serving customers, even in the middle of a cyber event, will be viewed far more favorably than those who focus solely on perimeter defenses.
A cybersecurity exam shouldn’t be seen as a hurdle, it’s an opportunity to validate the strength of your program and identify areas for real improvement. Institutions that prepare thoughtfully, document carefully, and integrate cybersecurity into their broader governance framework will be well-positioned for success.
If your bank or credit union is looking for help preparing for an upcoming cyber exam or just needs an outside perspective on your readiness, our vCISO team is here to support you. We specialize in helping institutions turn examiner expectations into operational advantages.
Let’s connect and make sure your next exam is your strongest yet.