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Quick Answer: NCUA examiners will prioritize board cybersecurity training, thorough IT risk assessments, vulnerability management, incident response playbooks, and AI oversight in 2026. Credit unions should update disaster recovery procedures, strengthen risk assessments, and implement scenario-based incident playbooks to pass exams confidently.
Why 2025 Findings Matter for 2026 Preparation
Examiner focus areas evolve gradually—last year's top findings typically persist, making them reliable predictors of future priorities. By analyzing 2025's most common issues, you can adjust your program proactively and avoid recurring compliance gaps.
An Examiner Approved Cyber Risk Model
Check out the Cyber Risk Management Model that examiners reference below
2025 NCUA Top Three Findings
1. Disaster Recovery and Business Continuity (Full Failover Testing Required)
The Gap: Many credit unions confuse technical disaster recovery (restoring systems) with business continuity (serving members without those systems). Examiners expect rigorous, real-world failover testing, not tabletop exercises.
Your Action Items:
- Schedule a full failover test by [DATE]
- Document clear separation between disaster recovery and business continuity procedures
- Validate vendor performance and internet operations during outages
- Test member-facing services in offline scenarios
- Create evidence file showing test results and improvements
2. IT/Information Security Risk Assessment (GLBA Cybersecurity Risk Assessment)
The Gap: Risk assessments lack depth. Many identify controls but fail to measure impact and likelihood of actual threats.
Critical Elements Examiners Look For:
- Threat Library – Named, specific threats (not generic categories)
- Impact & Likelihood – Quantified measurements, not just "high/medium/low"
- Control Testing – Evidence that key controls actually work
- Residual Risk Calculation – What risk remains after controls?
- Continuous Updates – Changes when threats or circumstances evolve
Your Action Items:
- Audit your risk assessment documentation for specificity
- Define and measure the impact and likelihood for each risk
- Document control testing schedule and results
- Set calendar reminders for quarterly assessments
- Create audit trail showing when/why assessments changed
3. Incident Response and 72-Hour Breach Notification Rule
The Gap: While most credit unions mention the 72-hour rule, few define what constitutes a reportable breach or provide clear escalation procedures.
Your Action Items:
- Write a clear definition: "Reportable breach = [your specific criteria]"
- Create a flowchart showing the escalation path and who must be contacted
- Ensure that any team member can understand when to escalate
- Conduct an incident response drill quarterly with a focus on timing
- Create a breach notification checklist for non-security staff
Five Key NCUA Priorities for 2026
1. Board Cybersecurity Training (New Priority)
Why It Matters: For the first time, examiners are making annual board cybersecurity training a top priority. Boards must move beyond passive awareness to active comprehension.
What Examiners Will Verify:
- Annual (or quarterly) cybersecurity briefings are formally documented
- Board members can interpret program metrics
- Training avoids technical jargon; focuses on risk and business impact
- Attendance records and materials retained
Implementation:
- Schedule annual minimum (quarterly preferred)
- Create one-page summaries with key decision points
- Use visual dashboards (charts, not code)
- Document meeting minutes, attendance, and materials
- Assess board comprehension through follow-up questions
2. Thorough IT Risk Assessment (Eight Essential Elements)
Why It Matters: NCUA now evaluates IT risk assessments against eight specific criteria. Missing even one element signals incomplete governance.
The Eight Essential Elements:
- Risk Appetite – Board-approved risk tolerance with quantified limits (not generic statements)
- Information Assets – Catalog of all data types (member PII, financial data)
- Systems – List of all IT systems processing those assets
- Risks – Identified threats to each asset/system combination
- Controls/Testing – Security controls with evidence that they work
- Measurement – Metrics tracking risk reduction over time
- Treatment – How residual risk is managed or accepted
- Reporting – Regular board/leadership reporting on risk status
Critical New Focus: Risk Appetite
Your "line in the sand" must be:
- Quantified: "Maximum 15% of systems can have critical vulnerabilities" (not "keep vulnerabilities low")
- Board-Approved: Explicitly approved, not buried in a policy
- Referenced: Tied to actual assessment results and decisions
- Enforceable: Triggers action when breached
Your Action Plan:
- Validate all eight essentials are covered in your assessment
- Develop risk appetite statement with quantifiable limits
- Present risk appetite to the board for approval (documented)
- Create an information asset inventory with classification
- Map systems to the asset types they process
- Define KPIs for each significant risk area
- Track trends showing improvement over time
3. Mature Vulnerability Management (Risk-Driven Process)
Why It Matters: Vulnerability management is evolving from "patch and scan" to a strategic, evidence-based process with measurable improvement and documented exceptions.
Key Components Examiners Review:
Scanning & Patching Integration
- Automated vulnerability scans on all systems with a documented schedule
- Straightforward process linking scan results to patch prioritization
- Documented patch timeline (e.g., "Critical patches within 30 days")
- Patch testing and deployment evidence
Key Performance Indicators (KPIs) Track at minimum:
- Critical vulnerabilities (target: declining trend)
- Exploitable vulnerabilities (target: declining trend)
- Mean time to remediation by severity
- Percentage of systems meeting patch policy
- Exception count and risk justification
Exception Handling & Documentation For systems that cannot be patched (e.g., legacy systems):
- Document the exception, why patching isn't possible, and compensating controls
- Identify who approved the exception
- Include the target resolution date
- Track when an exception can be revisited
Your Action Plan:
- Audit current scanning and patching workflows
- Consolidate into one integrated vulnerability management process
- Begin tracking KPIs with a historical baseline
- Formalize exception approval and tracking
- Review KPIs monthly; report to leadership quarterly
4. Incident Response Playbooks (Scenario-Specific)
Why It Matters: Generic incident response procedures aren't enough. Examiners expect scenario-specific playbooks for common attacks: ransomware, BEC, DDoS, data breaches, insider threats, and vendor incidents.
Playbook Components: Each scenario should include:
- Detection triggers (how do we know it's happening?)
- Initial response (isolate, notify, preserve evidence)
- Escalation path (who calls whom, in what order)
- Role assignments (specific titles/names, not just "CISO")
- Communication plan and timelines
- Recovery steps
- Post-incident procedures
Your Action Plan:
- Interview key staff (IT, operations, compliance, executive)
- Create scenario-specific checklists tailored to your systems
- Assign specific roles and current contact information
- Get executive approval
- Conduct a tabletop exercise for each scenario (validate and update playbooks)
- Update playbooks when staff changes or annually at a minimum
Examiner-Ready Evidence:
- Comprehensive incident response plan
- Scenario-specific playbooks (2-5 pages each)
- Tabletop exercise records with dates and findings
- Current contact list
- Board sign-off on procedures
5. AI Oversight (Emerging Priority)
Why It Matters: While concrete NCUA AI regulations haven't been finalized, examiners are already asking about AI use, policies, and risks. Proactive institutions get ahead of the curve.
AI Policy Must Cover:
- Approved AI use cases (what tools are allowed and where?)
- Data handling (what member data can be used?)
- Vendor management (how are AI vendors vetted?)
- Accuracy validation (how is AI output checked?)
- Oversight responsibility (who manages AI policy compliance?)
- Risk assessment (AI-specific risks documented?)
- Incident planning (what if AI provides wrong information?)
Key AI Risks Examiners Ask About:
- Member impact from inaccurate AI responses
- Data privacy and unauthorized vendor sharing
- Compliance errors from biased or incorrect models
- Cybersecurity vulnerabilities in AI systems
- Operational over-reliance and contingency planning
Your Action Plan:
- Draft AI Policy (even if minimal AI usage)
- Get board approval
- Assign AI Oversight lead (CIO or Chief Risk Officer)
- Update the IT risk assessment to include AI risks
- Review vendor agreements for data ownership and security
- Create a playbook for the "AI-Generated Misinformation" incident
- Define validation processes for AI outputs
- Document who's responsible for AI oversight
Quick Implementation Checklist
30 Days:
- [ ] Review previous exam report and identify gaps
- [ ] Assign exam prep leader
- [ ] Schedule board briefing on 2026 priorities
- [ ] Conduct self-assessment against five priority areas
- [ ] Start with highest-impact items
90 Days:
- [ ] Complete disaster recovery testing
- [ ] Finalize risk assessment with all eight elements
- [ ] Implement vulnerability management KPI tracking
- [ ] Create incident response playbooks
- [ ] Conduct first tabletop exercise
- [ ] Complete board cybersecurity training
Ongoing (Monthly/Quarterly):
- Update risk assessment when circumstances change
- Monitor and report KPI trends
- Board cybersecurity briefing
- Incident response validation (tabletop or drill)
- Annual full failover test
Exam-Ready Documentation Needed
- Documented failover test results with findings and corrections
- Current risk assessment with board-approved risk appetite
- Information asset inventory and system architecture
- Risk register with ownership assignments
- Control testing schedule and results
- Vulnerability management KPI dashboard with trends
- Incident response plan and scenario-specific playbooks
- Tabletop exercise records (annual minimum)
- Board meeting minutes documenting cybersecurity training
- AI policy and risk assessment (if applicable)
Final Takeaway
NCUA exams should not be a source of anxiety for well-prepared credit unions. Success requires three things: documentation (examiners review evidence, not intentions), measurable trends (KPIs showing improvement), and continuous improvement (treating exam prep as ongoing, not a crisis response).
By addressing the five 2026 priorities—board training, comprehensive risk assessment, mature vulnerability management, scenario-based incident playbooks, and AI oversight—your institution will not only pass the exam but also strengthen its risk management program and better protect its members.
An Examiner Approved Cyber Risk Model
Check out the Cyber Risk Management Model that examiners reference below