INSIGHT

Going beyond NCUA, FFIEC, and GLBA cybersecurity requirements: Actionable results

October 20, 2025

Your credit union passed its last exam. Your information security program checks all the regulatory boxes. Your policies are documented, your controls are mapped, and your board gets quarterly updates.

But compliance doesn’t equal security.

Meeting NCUA, FFIEC, and GLBA requirements establishes a baseline. It shows regulators you understand the fundamentals. But those frameworks weren’t designed to stop every threat your institution faces today. They outline minimum expectations, not maximum protection. The question isn’t whether you’re compliant. It’s whether you’re actually secure.

This article explores how credit unions and banks can move from checking boxes to building cybersecurity programs that address real-world risks.

Why minimum standards leave gaps

Regulatory frameworks focus on what’s measurable and enforceable across thousands of institutions. They address common risks and establish consistency. That’s valuable, but it also means they lag behind emerging threats.

By the time a cybersecurity control becomes a regulatory requirement, attackers have often moved on to new methods. Ransomware groups don’t wait for guidance updates. Neither do credential thieves or social engineers.

Your institution operates in a specific environment with unique risks. You serve particular members, use specific vendors, and face threats shaped by your geography, size, and digital footprint. Regulatory standards can’t account for all of that nuance.

“Numerous organizations have been compromised via misconfigured devices despite having a sound configuration management policy. As environments become more numerous, changes compound on each other and configuration creep occurs, resulting in vulnerable systems which can serve as footholds for attackers.” – Joshua Schmidt, BPM Cybersecurity Partner

What gets missed in compliance-focused programs

Compliance programs often emphasize documentation over outcomes. Institutions spend significant time proving they follow procedures, but less time testing whether those procedures actually work.

Consider incident response plans. Most institutions have one because regulations require it. But many plans sit in a drawer until an actual incident occurs. Teams discover gaps when they’re already under pressure, trying to contain a breach or restore systems while also figuring out who needs to be notified and when.

Testing reveals problems that documentation hides. Tabletop exercises show whether your team knows their roles. Simulated phishing campaigns reveal whether staff training actually changed behavior. Penetration testing finds vulnerabilities that policy reviews miss.

Another common gap involves monitoring. Compliance requires certain logs and controls, but often doesn’t specify how institutions should use that data. Many organizations collect the information but rarely analyze it. They meet the requirement without gaining the insight.

Building security that works, not just security that passes

Moving beyond compliance means shifting focus from “did we do this?” to “did this work?” It requires measuring outcomes, not just activities.

Start by understanding your actual risk profile. Regulatory risk assessments provide structure, but they shouldn’t be your only lens. Look at what’s really happening in your environment. Which systems hold your most sensitive data? Where do breaches typically start in institutions like yours? What would cause the most damage if it failed?

Next, prioritize based on impact. Not every control deserves equal attention. Some protect critical systems. Others address minor issues. Regulatory checklists treat requirements similarly, but your resources shouldn’t be distributed that way.

Test everything that matters. Don’t assume controls work because they’re documented. Verify them. Run exercises. Hire people to try breaking in. Review actual logs, not just policies about logs. When tests reveal problems, fix them before the next exam cycle forces you to.

Making cybersecurity practical

Better cybersecurity doesn’t always require bigger budgets. It often needs better focus.

Many institutions spend heavily on tools they barely use. They deploy software because a vendor promised it would solve problems, then struggle with implementation. Meanwhile, basic issues like inconsistent patching or weak password practices persist.

Focus on fundamentals first. Strong authentication matters more than most advanced tools. Regular patching prevents more breaches than expensive threat intelligence platforms. Clear accountability ensures controls actually get implemented and maintained.

Automation helps, but only when it’s solving real problems. Automated vulnerability scanning makes sense when you have a process for acting on results. Automated log analysis adds value when someone reviews the alerts. Technology without process just creates noise.

When compliance and cybersecurity align

The goal isn’t to ignore regulatory requirements. It’s to build programs where compliance happens naturally because you’re already doing what works.

When your incident response plan gets tested quarterly, updating it for examiners becomes straightforward. When you’re already monitoring for real threats, producing compliance reports takes less effort. When controls are designed around actual risks, they’re easier to justify and maintain.

This approach also improves examinations. Regulators respond well when institutions demonstrate they understand their risks and have thoughtful strategies for addressing them. They’re less impressed by perfect documentation that doesn’t reflect reality.

Working with BPM

BPM helps financial institutions build cybersecurity programs that work in practice, not just on paper. We understand regulatory requirements, but we focus on what actually protects your institution and your members.

Our team works with your staff to identify gaps, test controls, and develop practical improvements. We help you move from checkbox compliance to programs that address real risks. Whether you need support with risk assessments, incident response planning, or cybersecurity testing, we bring experience from working with institutions like yours. To discuss how we can help you go beyond basic compliance and build protection that works, contact us.