Cyberthreats continue to change, and financial institutions remain among the most frequently targeted organizations. Banks and credit unions are part of the nation’s critical infrastructure, making the protection of nonpublic personal information (NPI) and financial transactions a clear priority. That responsibility now spans ransomware, account takeover, mobile banking exploitation, and other forms of cybercrime. If you’ve just taken on the ISO title, that responsibility is now yours.

As the ISO, you hold a strategic role across technology and the business. The position carries visibility, responsibility, and accountability. You’ll work with the IT steering committee, board of directors, auditors, examiners, and other stakeholders to report on the institution’s information security program. The role can cover seven distinct areas of responsibility and 35 individual metrics that require reporting and documentation.

Strong ISOs bring leadership, organizational influence, a working command of regulatory requirements, and the ability to coordinate with internal management and third parties. They also need a detailed understanding of the institution’s technology infrastructure and operations. You need all of that, and you likely need to build it while still running the other roles you already hold. Most community banks and credit unions don’t employ a dedicated ISO, so the title and its accountability usually land on someone who already has a full plate.

If you’re stepping into the ISO role at a community financial institution, five areas deserve your immediate attention.

1. Ensure the Protection of Information

Your primary responsibility is protecting the security and confidentiality of NPI and the institution’s financial transactions. That means leading across administrative, technical, and physical controls, with each control matched to the institution’s risk. Information assets include paper records stored in a file cabinet, data housed in computer systems, and information transmitted over the internet, including remote deposit capture and mobile banking transactions.

2. Understand Key Regulations and Compliance Requirements

You need to understand and support compliance with the Gramm-Leach-Bliley Act (GLBA), also known as the Financial Modernization Act of 1999. GLBA requires financial institutions to explain how they share and protect customers’ private information and provides a durable framework for information security. The Federal Financial Institutions Examination Council (FFIEC) also establishes consistent guidelines, practices, and principles for financial institutions. Its 12 handbooks address information security requirements and accepted practices and are updated periodically. Both sets of expectations will shape how you build and document your program.

3. Build Proficiency in Cybersecurity and Cyber Assessment

The FFIEC describes cybersecurity as an evolving process for protecting consumer and bank information by preventing, detecting, and responding to attacks. The FFIEC’s Cybersecurity Assessment Tool (CAT) was designed to help institutions evaluate cyber risk and control maturity. You’re not required to use the CAT for your annual cyber assessment, but you are expected to assess your cyber posture each year and report the results to the board. The CAT has been a common methodology for measuring cybersecurity. You’ll also need familiarity with the FFIEC IT Examination Handbook and the standards that cover business continuity planning, IT and information security policies, audit, incident response planning, and related responsibilities.

4. Prepare for Responsibilities Beyond Proactive Security

No environment remains fully secure at all times. You need to be ready to coordinate a timely response to attempted or successful cyberattacks. That work may involve legal proceedings, communication with the cyber insurance carrier, and accountability for commercially reasonable security controls. The role also reaches into planning for infrastructure changes, growth or acquisitions, the institution’s IT and cyber risk appetite, risk assessments for new technology, and customer-facing online banking services.

5. Review Recurring Systems Management and Security Tasks

You need visibility into, and accountability for, the institution’s technology-driven security measures. Those measures include approved software, antimalware protections, software patching, encryption, and multifactor authentication designed to prevent unauthorized access. You should confirm that intrusion detection and prevention systems are adequate, review backup failures, and evaluate activity involving higher-risk online banking customers, including ACH and wire transactions.

Cybersecurity remains a persistent challenge for financial institutions, particularly smaller banks and credit unions operating with limited resources. As the ISO role expands, many institutions struggle to recruit and retain professionals with the range of expertise the position demands. Trusted third-party providers can add focused support and help you ensure that information security responsibilities are addressed on a consistent schedule.