Risk Management for Financial Institutions

Practical, regulator‑aligned, continuously updated risk management with automated gap analysis, POA&M tracking, and audit‑grade evidence.

Implement NIST‑aligned risk management with flexible mappings (COBIT, CIS, NIST CUI‑SSP). Automated gap analysis, POA&M tracking, and evidence vault to support exams and board reporting.

Overview

Under FDIC guidance, banks are expected to apply the NIST Risk Management Framework (RMF) to identify, select, implement, assess, and monitor cybersecurity and privacy controls. Credit unions are strongly encouraged to adopt similar RMF processes but may also use alternative, acceptable frameworks such as COBIT or the Center for Internet Security (CIS) controls and benchmarks. Trumbull’s IRM platform automates framework alignment, performs gap analysis, and produces a defensible Plan of Action & Milestones (POA&M) for each institution.

Why Framework Alignment Matters

  • The NIST RMF (NIST SP 800-37) lays out an organized lifecycle for managing security and privacy risk categories, control selection, implementation, assessment, authorization, and continuous monitoring — this has created a common expectation for Federal Examiners and many state/regulatory reviews.
  • Mapping controls to a widely accepted framework simplifies the examiner's review, reduces subjective judgment, and produces repeatable, auditable evidence packages.

IRM onboarding - actions carried out (automated and human validation)

Scope & BIA confirmation – We confirm which systems and business processes are GLBA/mission‑critical.

Framework mapping & gap analysis – The platform maps current controls to the NIST RMF (or selected alternative) and marks missing or partial controls as 'Planned' in the POA&M, generating an immediate prioritized remediation backlog.

Control verification & evidence capture – Automated checks provide time‑stamped evidence (logs, scans, configurations) stored in a tamper‑evident evidence vault.

Operational handoff – We execute POA&M items within your ITSM workflow and establish escalation rules, SLAs, and executive reporting cadence.

Result – A practical POA&M with assigned owners, deadlines, and measurable remediation impact — ready for internal audit and external examiners.,

Core IRM capabilities (aligned to Risk Management lifecycle)

Automated framework alignment: default NIST RMF, with mappings for COBIT, CIS, & NIST CUI-SSP.

Continuous monitoring: daily re-evaluation of CVEs, control drift, and telemetry to keep the risk profile current.

POA&M automation: auto-create, prioritize, and track remediation tasks.

Evidence vault & examiner packages: time-stamped, exportable artifacts to document control operation and remediation history.

Risk scoring & business impact linkage: vulnerability exploitability, asset criticality (BIA), and threat context linking to prioritize mitigation.

Ticketing & orchestration: two-way integration with ITSM to auto-create tickets and escalate when SLAs hit outstanding.

Strategic benefits (who wins and how)

Board and executives: brief reporting of risk trends and quantifiable ROI on remediation means.

Risk & compliance teams: evidence aligned to a framework that shortens exam cycles.

IT / SecOps: prioritized work queues, contextualized, and meaningfully tied back to the business impact.

Internal audit: repeatable, defensible sets of evidence, and POA&M histories that have less burdensome validation processes.

Finance: lower recurring expenses on external readiness projects and fewer expensive emergency fixes.

Implementation Roadmap

Phase 0 - Prepare (0–2 weeks)

Scope definition, stakeholder alignment, BIA confirmation.

Phase 1 - Discover (2–5 weeks)

Deploy collectors, reconcile asset inventory, baseline controls.

Phase 2 - Map & Automate (5–10 weeks)

Run framework mapping, configure daily CVE ingestion, and control tests.

Phase 3 - Integrate & Operate (10–14 weeks)

ITSM integration, runbooks, tabletop exam readiness.

Phase 4 - Continuous Improvement (Ongoing)

Tuning risk models, quarterly executive reporting, extending coverage.

Roles & responsibilities (recommended)

Board/Executive Sponsor: Attest to appetite, cadence of reporting.

CISO / Head of Risk: oversee program, validate risk models.

Risk & Compliance: define framework selection and reporting templates.

SecOps / IT: remediate, verify, and close POA&M items.

Internal Audit: independent validation and re-testing of controls.

FAQ

Do banks have to use NIST RMF?
FDIC guidance expects bank management to apply a NIST-consistent RMF for IT systems; this has become the practical standard for many examiners. Trumbull supports NIST RMF out of the box.
Can credit unions use alternatives like COBIT or CIS?
Yes. The NCUA allows the use of alternative frameworks; Trumbull maps controls to COBIT, CIS, and other accepted frameworks during onboarding.
How does this help with exams?
The platform produces segmented, time-stamped evidence and a POA&M history that examiners can review, reducing back-and-forth requests and accelerating acceptance.
What if our CMDB is incomplete?
Automated discovery collectors build the inventory and reconcile gaps against your CMDB during onboarding, improving accuracy and reducing manual effort.

Ready to Strengthen Your Risk Program?

Contact: irm@trumbullsecurityservices.com