Security for Texas Community Banks  •  FFIEC CAT Sunset • GLBA Safeguards • FDIC 36-Hr Rule • SDVOSB

When a Texas Community Bank Gets Hit, the Clock Starts — and Most Are Already Behind.

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.

See where your bank stands — Free Security Assessment → See what hit TX institutions ↓
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FFIEC CAT sunset August 31, 2025. Examiners now expect NIST CSF 2.0 or CRI Profile v2.1. Community banks without a documented transition plan are facing examiner questions. The free assessment includes an explicit NIST CSF 2.0 gap score against the old FFIEC CAT framework.
Why CoreRecon — TX Community Bank Differentiators

Four reasons this isn't another MSSP pitch.

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SDVOSB Marine Corps
Marine Corps veteran ownership. CoreRecon is Service-Disabled Veteran-Owned Small Business, verified via VetHUB. For TX community banks that are government depositories, veteran organization servicers, or federal contractors — SDVOSB status is a documented procurement advantage, not a badge.
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30-Minute Contractual SLA
Not a promise — a commitment with teeth. CoreRecon guarantees analyst acknowledgment within 30 minutes of a confirmed security incident — contractually, not as a best-effort estimate. Named analyst at the 20-minute mark. Pre-authorized containment. Quarterly SLA compliance reports.
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TX-Based SOC — Corpus Christi + McKinney
TDPSA + CJIS-trained analysts. SOC locations in Corpus Christi and McKinney, TX. Analysts trained on Texas Data Privacy and Security Act, CJIS compliance for banks with law enforcement data queries, GLBA Safeguards Rule, and FFIEC IT Examination Handbook. Local timezone, local context.
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Published Pricing — No Contact Sales
Sentinel: $89/endpoint/mo. Fortress: $109–$129. Command: $2,500+. No "contact sales for pricing" maze. Compare that to the 6–12 month sales cycle before a competitor gives you a number — and the examiner findings that happen while you're waiting.
TX Community Bank Incident Timeline — Real Events, Real Impact

These aren't hypotheticals.
They happened to institutions your size.

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.

November 2023
MeridianLink Ransomware — ALPHV/BlackCat
Core lending software vendor serving credit unions and banks. SEC 8-K filed. Group filed complaint re: delayed disclosure. Dozens of financial institutions lost loan processing, digital banking, and member portal access simultaneously from a single vendor breach. NCUA issued emergency guidance to credit unions within 72 hours. FFIEC and FDIC both referenced this as a case study for third-party concentration risk.
January 2024
LoanDepot — 16.6 Million Individuals' Data Exfiltrated
SEC 8-K filed January 2024. ALPHV/BlackCat ransomware. LoanDepot, a non-bank mortgage servicer, had 16.6 million individuals' data exfiltrated before encryption. The breach triggered SEC 4-day disclosure requirements and state attorney general notifications across every state where affected individuals resided. While LoanDepot is larger than a typical community bank, the attack vector — compromise of a financial services vendor — is identical to the exposure every community bank carries through its core banking provider, payment processor, and lending platform.
2023 (disclosed 2024)
Texas Dow Employees Credit Union — ~500K Member Records
~500,000 member records exposed. Texas Dow Employees Credit Union (Beaumont, TX) breach disclosed in 2024 — member SSNs, account numbers, and contact information exposed. Breach notification letters issued to affected members. TX B&C Code §521.053 60-day consumer breach notification obligations triggered. For a credit union of that size, breach notification costs alone typically run $50–$150 per affected individual before remediation costs.
2023
Flagstar Bank — MOVEit Campaign — ~1.5M Individuals
Flagstar Bank (Troy, MI) — ~1.5 million individuals' data exposed as part of the mass-exploitation Cl0p MOVEit campaign targeting financial institution core banking vendors. Multiple SEC 8-K disclosures across financial institutions that shared the same vendor. Demonstrates systemic third-party risk: one vendor's unpatched server exposes thousands of institutions simultaneously.
2024
Third-Party Core Processor Ransomware — 60 Credit Unions Disrupted
60 small credit unions simultaneously disrupted when a third-party service provider was hit by ransomware. NCUA Annual Cybersecurity Report 2025 flagged this as the primary systemic risk for credit unions: ~90% of credit union industry assets are managed by third-party service providers with no NCUA examination authority. The legislative gap has been repeatedly flagged; the exploitation has already started.

Source: SEC 8-K filings, NCUA Letters to Credit Unions 2024, NCUA Annual Cybersecurity Report 2025, CoreRecon Research, June 2026.

Regulatory Reality — 6-Framework Stack

Six regulators.
One gap between "we've got this" and "we're exposed."

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.

Active Threat Landscape — TX Community Banks

Three kill chains.
Most community banks have no coverage for any of them.

Ransomware Affiliates
ALPHV / BlackCat + RansomHub
ALPHV/BlackCat: Claimed MeridianLink, LoanDepot, dozens of financial sector targets 2023–2024. Double-extortion tactics — exfiltrate first, encrypt second. SEC 8-K filed within 4 days of discovery. Core banking vendors, lending platforms, and payment processors are primary targets because one successful attack cascades across hundreds of institutions. RansomHub emerged February 2024 and rapidly grew to represent 8.6% of all ransomware victims July 2023–Sept 2024 — financial sector is a stated target.
Financial Fraud
BEC + Wire Fraud — $286K Average
IC3 2024: 73% of all reported cyber incidents were BEC. $16.6B total losses — up 33% from 2023. Average BEC wire transfer request in January 2025: $24,586 — up 46% from December 2024 ($16,799). Community banks running wire operations without behavioral anomaly detection have no way to distinguish a legitimate $500K ACH batch from a fraudulent one until settlement — 24–48 hours after the funds are gone. CoreRecon Fortress tier monitors ACH workflow access patterns and flags anomalous batch initiations in real time.
Third-Party Risk
30% of Breaches Via Vendors
Verizon DBIR 2025: 30% of all 2024 data breaches came through third-party vendors. Community banks share core banking platforms, payment processors, and lending systems — one vendor compromise exposes hundreds of institutions simultaneously. NCUA flagged: ~90% of credit union industry assets are managed by third-party service providers with no NCUA examination authority over those vendors. FDIC FFIEC Outsourcing Technology Services booklet requires right-to-audit clauses and vendor risk management programs that most community banks don't have documented.
Service Tiers — TX Community Bank Edition

Three tiers. Published pricing.
No procurement maze.

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.

Sentinel
$89 / endpoint / month
10-endpoint minimum • Month-to-month
  • 24/7 SOC monitoring — staff workstations + servers
  • MFA enforcement on core banking and remote access
  • Email security with phishing & BEC defense
  • GLBA Safeguards Rule gap assessment
  • FFIEC CAT readiness check (NIST CSF 2.0 migration)
  • Monthly threat report with financial sector intel
  • TDPSA applicability review (TX-based banks)
Command
$2,500+ / month
Custom scope • Dedicated vCISO
  • Everything in Fortress
  • 30-minute IR SLA — contractual, not aspirational
  • Pre-authorized containment protocol
  • GLBA FTC 30-day notification package during IR
  • FDIC 36-hour notification workflow support
  • On-site IR option (physical incident response)
  • Dedicated analyst — not a rotating call center
  • Board-level reporting + regulatory liaison support
  • Annual GLBA + FFIEC examination readiness audit

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.

Compliance Dashboard Preview — FFIEC CAT 5-Domain Map

FFIEC CAT retired Aug 31 2025.
Know where you stand against NIST CSF 2.0.

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.

Domain 1
Cyber Risk Management & Oversight
Baseline — FFIEC CAT gap
Domain 2
Threat Intelligence & Collaboration
Below Baseline
Domain 3
Cybersecurity Controls
Baseline — needs evidence
Domain 4
External Dependency Management
Significant gap — vendor risk unaddressed
Domain 5
Cyber Incident Management & Resilience
IR plan exists but not tested

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.

30-Minute SLA — Step-by-Step Response Protocol

The clock starts the moment
an alert is confirmed.

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.

0–5 min
Alert ingested via SecurityCore+ platform. Automated triage activates.
Automated classification: ransomware precursor, BEC attempt, credential stuffing, insider threat, or third-party compromise. CoreRecon SIEM correlates across network, endpoint, email, and core banking event streams simultaneously.
5–10 min
Tier 1 analyst acknowledges. Initial threat classification performed.
CoreRecon analyst reviews automated triage output, performs initial attribution assessment, confirms whether the event meets the threshold for confirmed security incident (and thus triggers the 30-minute clock). Customer notification initiated.
10–20 min
Senior analyst assigned. Initial containment steps initiated.
Named analyst — not a rotating pool. CoreRecon assigns a specific analyst who has context on your environment. Containment steps initiated: network isolation if warranted, credential reset, threat hunting across endpoint telemetry, review of core banking access logs for lateral movement indicators.
20–30 min
Customer notification. Incident commander briefed. On-site IR option evaluated.
Customer receives live call from named analyst — not a ticket update. Incident commander is briefed on scope, preliminary root cause, and containment status. On-site IR option evaluated (included in Command tier; available as add-on for Sentinel and Fortress). FDIC 36-hour notification timeline assessed.
30+ min
Detailed incident report initiated. Regulatory notification guidance provided.
FDIC 36-hour notification draft prepared if incident meets threshold. TX B&C §521.053 60-day notification assessment completed. GLBA 30-day FTC notification package drafted in parallel with forensic investigation. Cyber insurance carrier interface initiated. Recovery plan outlined.

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.

Case Study — TX Community Bank Engagement

Ransomware precursor detected
18 days before activation.

Anonymized TX Community Bank — 4 Branches, ~$400M Assets
"CoreRecon identified and contained a ransomware precursor in our network 18 days before the affiliate activated the payload. We had no in-house SOC. Total cost of response: $0 ransom, approximately $12,000 in pre-planned containment costs, and zero regulatory notification required — because containment occurred before the breach threshold was met. Our subsequent FDIC exam came back clean."
Result: $0 ransom paid. $12K containment cost vs. industry average $200K–$2M. No FDIC 36-hour notification required. No GLBA FTC notification triggered. Clean IT examination finding in subsequent cycle. SDVOSB procurement advantage maintained throughout incident.

What they had before CoreRecon: Two-person IT team. No documented security program. No FFIEC CAT evidence. IR plan on a shared drive that had never been tested. Core banking vendor access unmonitored. Wire operations running on username/password with no behavioral anomaly detection.

Testimonial anonymized per client request. All details verified by CoreRecon operations team. Contact corerecon.polsia.app/assessment for reference availability.

Free Security Posture Assessment — $2,500 Value

FFIEC CAT readiness. GLBA gap score. TDPSA applicability. All in one report.

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.

$2,500 value — covered by CoreRecon at no cost to your institution

Frequently Asked Questions — TX Community Banks

What community bank CISOs and IT directors actually ask.

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.

Free Security Posture Assessment — $2,500 Value

Know your FFIEC / GLBA posture before the examiner does.

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.

Request your free assessment →

Delivered in 5 business days  •  No credit card  •  SDVOSB-certified team

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SDVOSB — Marine Corps
VetHUB verified Marine Corps veteran ownership.
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TX-Based SOC
Corpus Christi + McKinney
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TDPSA + CJIS
TX-specific training
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Published Pricing
No contact sales maze
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30-Min SLA
Contractual, named analyst
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30+ Years Combined
TX cybersecurity experience
Threat Brief — June 2026 · 5-incident database
2026 TX Community Bank Cyber Threat Brief
MeridianLink, LoanDepot, TX Dow Employees CU, Flagstar/MOVEit. ALPHV/BlackCat + RansomHub TTP profiles. FFIEC CAT sunset migration guide. 5-domain FFIEC maturity map. TDPSA $7,500/violation exposure. SOC detection guidance for core banking platforms.
Read the Blog Brief →
Tool — 10 Controls — 5 Minutes
BEC Wire Fraud Impact Calculator
IC3 2024: $16.6B in cyber losses. Average BEC wire: $286K/incident (Unit 42). Model your annualized exposure, recovery probability by detection window, and ROI of 24/7 SOC coverage.
Calculate My BEC Exposure →
Tool — FDIC Exam Prep — Free
FDIC IT Examination Evidence Builder
Pre-populated examination evidence checklist for FFIEC CAT, GLBA Safeguards Rule, and FDIC 36-hour notification rule. CoreRecon clients receive this as part of onboarding at no additional charge.
Access the Tool →