Community banks, credit unions, RIAs

The examination, the ISE, Regulation S-P, and the document request list. We know the paper each one arrives on.

What arrives

The exam, and the MRA
The examination itself, and the Matters Requiring Attention it leaves behind. The FFIEC Cybersecurity Assessment Tool sunset on 31 August 2025, and the expectation to measure and manage did not.
The ISE
The NCUA Information Security Examination, with its SCUEP, CORE and CORE+ tiers, each control needing evidence in hand.
Reg S-P
The SEC Regulation S-P amendments. An incident response program, 30-day individual notice, and a compliance date of 3 June 2026 for smaller entities.
The document request list
The SEC Division of Examinations request list, including a complete inventory of every vendor with access to customer information.
The 72-hour rule
NCUA cyber incident notification under 12 CFR Part 748, running from when the incident is reasonably believed to have occurred.

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A short, plain conversation about the outside view, with an advisor who knows the paper.