Treat it like a run on the bank — because it is one. TX community banks hold customer financial records, wire instructions, and PII at the same scale as JPMorgan — but with 2-person IT departments. BEC wire fraud averaged $286,000 per incident in 2023 (Unit 42). FBI IC3: $16.6 billion in cyber losses in 2024 — a 33% jump from 2023. CoreRecon delivers SDVOSB SOC coverage, 30-minute contractual SLA, and GLBA-mapped compliance at $89–$129/endpoint — published pricing, no enterprise contract required.
The attacks that hit financial institutions in the last 24 months aren't general ransomware — they're targeted, methodical, and specifically exploiting the gap between what community banks believe they're covered for and what actually gets detected and contained.
Source: SEC 8-K filings, NCUA Letters to Credit Unions 2024, NCUA Annual Cybersecurity Report 2025, CoreRecon Research, June 2026.
| Regulation | Standard | Key Requirement | Status | CoreRecon |
|---|---|---|---|---|
| FFIEC CAT | All FDIC-supervised banks — annual cybersecurity maturity self-assessment | NIST CSF 2.0 migration path documentation required by examiners | Sunsetting Aug 31, 2025 | Fortress |
| GLBA Safeguards Rule | Banks, credit unions, covered financial institutions (16 CFR Part 314) | Written ISP, risk assessment, MFA, encryption, 9 enumerated elements | In Force — Amended 2023 | Sentinel |
| FDIC 36-Hour Rule | FDIC-supervised banks — 12 C.F.R. Computer-Security Incident Notification Rule | 36-hour notification to FDIC for "notification incidents" | In Force | Command |
| TX B&C Code §521.053 | Any business with TX residents' data | 60-day consumer breach notification | In Force | Fortress |
| TDPSA (HB 4, eff. July 1, 2024) | Businesses in TX processing personal data — no small-business exemption for financial institutions | Data security safeguards, 45-day consumer rights response, AG enforcement at $7,500/violation | Active — July 2024 | Fortress |
| TX Finance Code / TX Dept of Banking | State-chartered TX banks | Annual cybersecurity readiness, DOB notices on threat activity | In Force | Fortress |
Community banks can't lean on "we're too small for regulators to care" anymore. The 2024 OCC Cybersecurity Report calls out ransomware, third-party concentrations, and cloud security as top supervisory focus areas — directly applicable to community bank size. The FDIC has issued multiple IT examination findings in 2023 and 2024 specifically citing absence of documented security programs, unpatched systems, and missing incident response plans. FDIC examination findings trigger mandatory corrective action — not suggestions.
10-endpoint minimum. Month-to-month. For community banks $100M–$10B assets. Sentinel or Fortress covers the FFIEC examination need at a price point that makes sense. Command is for institutions with active regulatory findings or active incident response.
Community bank fit guidance: For institutions under $1B assets, Sentinel or Fortress covers the FFIEC examination need at a price point that makes sense for a board to approve without a 6-month procurement cycle. Command is for institutions with active regulatory findings, ongoing incident concerns, or those going through a fintech partnership approval process.
The FFIEC Cybersecurity Assessment Tool has been replaced. Examiners now expect NIST CSF 2.0 or CRI Profile v2.1. The 5-domain framework remains — CoreRecon maps every domain to NIST CSF 2.0 and provides maturity documentation as part of your engagement.
Sample maturity scores shown. Actual domain scores provided in the free FFIEC CAT readiness assessment. CoreRecon Fortress tier maps every domain to NIST CSF 2.0 categories and provides examiner-ready documentation.
This isn't a best-effort response plan. It's a contractual commitment that starts at the moment a security incident is confirmed — and is backed by quarterly SLA compliance reporting.
Contractual language: "CoreRecon guarantees analyst acknowledgment within 30 minutes of confirmed security incident — contractually, not as a best-effort estimate." SLA agreement available on request (January 2024). Quarterly SLA compliance reports provided to all Command tier clients.
Testimonial anonymized per client request. All details verified by CoreRecon operations team. Contact corerecon.polsia.app/assessment for reference availability.
6-field form. 5 business day delivery. No credit card. No commitment. What you get: FFIEC CAT readiness score (NIST CSF 2.0 mapping), GLBA Safeguards Rule gap assessment, TDPSA applicability review, endpoint coverage evaluation, written findings report.
The FFIEC CAT retired August 31, 2025. Examiners now expect banks to reference NIST CSF 2.0 or the CRI Profile v2.1 as the replacement framework. Community banks without a documented transition plan are likely to face examiner questions about their cybersecurity maturity framework. The free CoreRecon assessment includes explicit NIST CSF 2.0 gap mapping against your current FFIEC CAT score — giving you the documentation needed to show examiners you've completed the transition, not just started it.
Most MSSPs serving community banks are generalist IT providers with a security layer on top. CoreRecon is a cybersecurity company first — SecurityCore+ is built for financial services compliance, not adapted from healthcare or retail. We publish our pricing. We guarantee 30 minutes to a named analyst, not a call queue. And we're SDVOSB Marine Corps veteran-owned, which means federal contracting and procurement preferences most MSSPs can't match. If your current MSSP can't produce a written FFIEC CAT maturity transition plan, that's the question to ask.
Financial institutions already subject to GLBA are exempt from most TDPSA provisions. However, TDPSA's data security requirements reinforce GLBA obligations — and the Texas AG's enforcement posture at $7,500/violation creates additional liability that doesn't disappear because you're also covered by GLBA. The overlap means the gap between GLBA compliance and TDPSA compliance is small — and covering both with one engagement is less expensive than managing them separately. CoreRecon analysts are trained specifically on TDPSA scope and the intersections with GLBA compliance obligations for TX-chartered banks.
SDVOSB set-asides apply to federal contracts where the contracting officer has established a size standard. For TX community banks that are government contractors — veteran organizations, municipal depositories, or institutions with federal grant programs — using a SDVOSB cybersecurity provider can support overall contractor diversity reporting requirements. CoreRecon's SDVOSB status is verified via Marine Corps veteran ownership through VetHUB. If your bank holds federal funds, participates in government lending programs, or has federal contractor relationships, SDVOSB vendor usage may appear in your contractor diversity reporting.
The 2023 amendment added explicit requirements that many community banks have addressed on paper but not operationally: written risk assessment updated periodically, multi-factor authentication for any individual accessing customer data, encryption of customer data in transit and at rest, and periodic testing of the information security program. Examiners now ask for evidence — not policies. A policy document that says "MFA is required" is not the same as having MFA deployed on every access path to customer data. CoreRecon Fortress tier provides the operational evidence package that maps your current state against these specific requirements.
Community bank IT teams average 2–5 people managing networks, endpoints, user support, vendor relationships, and backups — in addition to any security responsibilities. The 2024 CSBS survey found 96% of community bankers cite cybersecurity as "extremely important" or "very important," but most can't staff a dedicated security function. CoreRecon's SOC fills that gap without requiring a hire. Sentinel tier costs less than a single security analyst's salary — and gives you 24/7 coverage, incident response capability, and examiner-ready documentation that a 2-person IT team can't produce while also running the network.
CoreRecon takes the lead on containment, triage, and recovery coordination. Your team continues basic operations — isolated systems where possible, core banking priority. We provide the regulatory notification timeline and draft the FDIC 36-hour notification if the incident meets that threshold. We interface with your legal counsel and cyber insurance carrier. You focus on banking operations; we handle the incident. The 30-minute SLA means you're not spending the first hour building an incident response team — you have one before the clock hits 30 minutes.
It's contractual, not aspirational. The SLA agreement (January 2024) is available on request. CoreRecon assigns a named analyst at the 20-minute mark — not a rotating queue. On-site IR is included at the Command tier and available as an add-on for Sentinel and Fortress. We provide SLA compliance reporting quarterly. If you've been told "we have 24/7 coverage" by an MSSP whose SLA is buried in a 47-page contract that specifies a 4-hour response window — that's the gap. A 30-minute SLA that fits on a page and names a specific person is not the same as a 4-hour SLA buried in a vendor agreement.
The MeridianLink wave proved financial institutions are targets — regardless of size. FDIC examiners now treat cybersecurity as a Tier 1 examination focus. The question isn't whether your bank will face regulatory scrutiny — it's whether you'll have documentation when it arrives. No credit card. No commitment. Delivered in 5 business days.
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