Your examiner wants to see a “comprehensive cybersecurity risk assessment.” You have one quarter to produce it.
You Google “bank cybersecurity risk assessment.” The first three results are 90-page whitepapers from consulting firms, templates that require a PhD to understand, and frameworks designed for banks 50 times your size.
This is the problem with cybersecurity advice for community banks. It assumes you have a security team, a CISO, and unlimited budget. You have Carol from compliance who also handles HR, and maybe IT Jim who swears he’s “keeping an eye on things.”
The Real Security Gap Isn’t What You Think
Community banks don’t fail security because they lack enterprise-grade tools. They fail because:
Nobody’s telling them what actually matters. You’re drowning in vendor pitches for acronyms you don’t understand (EDR, XDR, MDR, SIEM) and tools you can’t pronounce. Meanwhile, your backup strategy is “pray and hope,” and half your staff uses the same password for everything.
Compliance doesn’t equal security. You can check every box on your examiner’s list and still get ransomwared next Tuesday. The reverse is also true: you can have solid security fundamentals and get dinged for not having the right paperwork.
The guidance is written for banks that aren’t you. NIST CSF 2.0 has 106 outcomes across 23 categories. NIST 800-53 has over 1,000 controls. The CIS Controls have 153 safeguards. Even banks with $10M IT budgets struggle with that. You don’t stand a chance.
What Community Banks Actually Need
After 20+ years in security, including time at a regional bank that grew from $10B to $20B, here’s what I know works for smaller institutions:
1. Start with the CIS Controls - The First Five
Forget all 153. Focus on these:
- Asset inventory - You can’t protect what you don’t know exists
- Software management - Unpatched systems are how you get breached
- Data protection - Know where sensitive data lives and who can access it
- Account management - Former employees shouldn’t still have access
- Access control - Not everyone needs admin rights
That’s it. Master those five before you worry about advanced threat hunting.
These aren’t “nice to have” or “aspirational goals.” These are the fundamentals that prevent 85% of attacks. Get these right and you’re ahead of most community banks. Skip them and no amount of expensive security tools will save you.
Your examiner might ask about your SIEM or your threat intelligence platform. But if you can’t answer “who has access to what” or “how quickly do you patch critical vulnerabilities,” those fancy tools don’t matter.
Start here. Get good at these five. Then think about what comes next.
2. Stop Trusting Your MSP Has Everything Covered
Your IT is outsourced to an MSP. They handle patches, backups, monitoring. Your examiner sees “managed security services” on the invoice and checks the box.
But here’s what I see when I walk into community banks:
The MSP installed endpoint protection two years ago. Nobody’s looked at the alerts since. Half the endpoints aren’t reporting in. The MSP says “everything’s fine” in their monthly report.
Your backup solution runs every night. Great. When’s the last time you actually restored from backup? Does your MSP test that? Do you know for sure you can recover?
The firewall logs show thousands of blocked connections. Your MSP sends you a monthly summary. But who’s actually reviewing those logs for patterns? Who’s looking for successful attacks, not just blocked ones?
Trust but verify.
Your MSP might be great. But they’re managing dozens or hundreds of clients. You need to know:
- What are they actually monitoring?
- How quickly do they respond to alerts?
- What’s their process for patching critical vulnerabilities?
- Do they test your backups?
- Who reviews their monthly reports with actual security expertise?
Get a quarterly security review from someone who isn’t your MSP. Not to replace them, but to verify they’re doing what you’re paying them to do. Think of it like an audit - you trust your accounting team, but you still get audited.
Better to find gaps now than during an incident or examination.
3. Know When to Call for Help
Some things you can handle in-house:
- User security awareness training
- Basic access reviews
- Vendor questionnaire responses
- Policy updates
Some things need outside expertise:
- Incident response (you need a retainer BEFORE something happens)
- Penetration testing
- Security architecture for new systems
- Anything involving the word “forensics”
The trick is knowing which is which before your examiner does.
The Risk Assessment That Actually Works
Your examiner wants a risk assessment. Here’s what they’re really asking:
- Do you know what you have?
- Do you know what’s important?
- Do you know what could go wrong?
- Have you done something about it?
That’s it. Not 90 pages of boilerplate. Four questions with real answers.
Start with your core banking system. What happens if it goes down? What happens if someone gets unauthorized access? What are you doing to prevent that?
Then move to your backup systems, your ACH processing, your wire transfers. Work through what matters, not what some framework says you should document.
The Part Nobody Talks About
Here’s what keeps me up at night about community bank security: the human element.
Your biggest risk isn’t sophisticated nation-state hackers. It’s:
- Betty in branch operations who clicks on everything
- The executive who demands admin access “because I’m an executive”
- The vendor who needs “temporary” remote access that becomes permanent
- The off-site backup storage that nobody’s verified in months/years/ever(?)
Technology can’t fix those. Only culture and training can.
What This Actually Looks Like
A real community bank security program:
- Quarterly access reviews (who can do what, and should they?)
- Backup testing (can you actually restore from those backups?)
- Vendor reviews (are your critical vendors still secure?)
- Incident response plan that people have actually practiced
None of this requires six figures. It requires consistency and someone who gives a damn.
The Community Bank Security Starter Kit
I built the Community Bank Security Starter Kit because I got tired of watching community banks struggle with advice designed for banks 100 times their size.
Inside:
- CIS Controls scorecard you can actually fill out
- Guide on when to hire outside help vs. handle it yourself
- Quick wins that satisfy examiners without breaking your budget
- Plain English explanations for technical security concepts
No consultant speak. No enterprise-only advice. Just practical security for banks that need to get it done.
The Bottom Line
Your community bank doesn’t need enterprise security. You need security that works for your size, your budget, and your reality.
Start with what matters. Focus on the basics. Know when to call for help. That’s not sexy, but it works.
And when your examiner comes back next quarter, you’ll have real answers instead of vendor brochures.
Looking for practical security guidance for your community bank? Download the Community Bank Security Starter Kit. Or reach out if you need a fractional CISO who actually understands community banking.