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Financial institutions

Penetration Testing for Banks and Credit Unions

Banks and credit unions answer to examiners who read the FFIEC handbooks, to card networks, and in New York to the Department of Financial Services. Invadel provides penetration testing for financial institutions at a fixed price, covering online banking, internal networks, and staff, with a free retest and an attestation letter for the exam file.

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The stakes

Why banks and credit unions get tested differently

Attackers target financial institutions for the money and for the trust. Account takeover of online and mobile banking through weak reset flows and session handling, business email compromise that ends in a fraudulent wire, ransomware that walks from a branch workstation to the core connection, and abuse of the file-transfer and VPN links to core and payment vendors are the patterns that recur in incident reports year after year.

The examiners arrive with expectations already written. The FFIEC Information Technology Examination Handbook treats penetration testing and vulnerability assessment as standard components of an institution’s assurance program. The GLBA Interagency Guidelines for banks and NCUA Part 748 for federally insured credit unions call for regular, independent tests of key controls. New York-chartered and licensed institutions owe annual testing under NYDFS 23 NYCRR 500.5, the FTC’s Safeguards Rule names annual testing for non-bank lenders, and any card program brings PCI DSS.

A generic test misses the shape of a financial institution. Online banking is usually hosted by a digital banking vendor and can only be tested with that vendor’s authorization and within its rules. The internal network mixes branch workstations, teller systems, and back-office servers with vendor connections that must be handled with care. The report has to tie findings to the institution’s risk assessment and read the way an examiner expects. We scope, coordinate, and write for that audience.

What we test

The systems attackers go after first

01

Online and mobile banking

The customer and business banking portals and apps, often vendor-hosted, tested for account takeover, authorization flaws between customers, and weaknesses in enrollment, reset, and transaction flows.

02

Payment origination and vendor connections

Wire and ACH origination portals, file transfers to the core and card processors, and the VPN and API links to vendors, tested for the trust an attacker could borrow.

03

Branch and back-office network

Active Directory, teller and loan workstations, back-office servers, and the segmentation between them, tested from an assumed foothold for the path to the core connection.

04

Employee identity and email

The Microsoft 365 or on-premises identity that authorizes wires and approvals, tested for multi-factor gaps, mail-rule abuse, and the business email compromise paths that produce fraudulent payments.

05

Public website and loan applications

The marketing site and the online account and loan application forms that collect Social Security numbers and income data, tested for injection, exposure, and abuse.

06

Cloud and imaging systems

Document imaging, loan origination, and the cloud services that hold customer records, tested for identity and configuration paths that expose nonpublic personal information.

Compliance

The frameworks that usually apply

  • NYDFS 23 NYCRR 500

    The annual penetration testing and vulnerability assessments that section 500.5 requires of New York-chartered and licensed institutions.

  • PCI DSS

    Requirement 11.4 testing for card issuing, acquiring, and any environment that stores or transmits cardholder data.

  • SOC 2

    The independent testing evidence fintech partners and technology vendors to the institution are asked for in vendor management reviews.

  • FTC Safeguards Rule

    The GLBA rule for non-bank lenders, mortgage companies, and finance companies: annual penetration testing and vulnerability assessments every six months under 16 CFR 314.4(d)(2), absent effective continuous monitoring.

Services

What banks and credit unions usually buy

Regulations

Which banking regulations require penetration testing

NYDFS, the FTC Safeguards Rule, and PCI DSS name penetration testing and a frequency outright. The bank and credit union rules call for regular, independent testing of key controls and leave the method and frequency to your risk assessment. Examiners then read the results against the FFIEC handbook.

FFIEC IT Examination Handbook, Information Security booklet

Who it covers
Institutions examined by the FFIEC member agencies, including banks and credit unions
What it asks for
Lists penetration tests and vulnerability assessments among the primary assurance and testing tools, and expects management to review the qualifications of the testers.
How often
Set by the institution’s risk assessment. Changes to networks, systems, or applications are among the factors that call for more frequent testing.

GLBA Interagency Guidelines, Section III.C.3

Who it covers
Banks supervised by the OCC, the Federal Reserve, and the FDIC
What it asks for
Regular tests of the key controls, systems, and procedures of the information security program, run or reviewed by independent third parties or independent staff.
How often
As often as the bank’s risk assessment calls for.

NCUA Part 748, Appendix A, Section III.C.3

Who it covers
Federally insured credit unions
What it asks for
The same standard: regular tests of key controls, run or reviewed by independent third parties or independent staff.
How often
As often as the credit union’s risk assessment calls for.

NYDFS 23 NYCRR 500.5

Who it covers
New York-chartered banks, trust companies, and other institutions licensed by the Department of Financial Services
What it asks for
Penetration testing from inside and outside the information systems’ boundaries by a qualified internal or external party, plus automated vulnerability scans with manual review of systems the scans miss. See NYDFS 23 NYCRR 500 penetration testing.
How often
Penetration test at least annually. Scans at a frequency set by the risk assessment and promptly after material system changes.

FTC Safeguards Rule, 16 CFR 314.4(d)(2)

Who it covers
Non-bank financial institutions such as mortgage lenders and brokers, finance companies, and tax preparation firms
What it asks for
Annual penetration testing and vulnerability assessments, unless the institution runs effective continuous monitoring. Institutions holding customer information on fewer than 5,000 consumers are exempt from this paragraph. See FTC Safeguards Rule penetration testing.
How often
Penetration test annually. Vulnerability assessments at least every six months and after material changes.

PCI DSS Requirement 11.4

Who it covers
Any institution that stores, processes, or transmits cardholder data, including card issuing programs
What it asks for
Internal and external penetration testing of the cardholder data environment, a retest of fixed findings, and segmentation testing where scope is reduced. See PCI DSS penetration testing.
How often
At least once every 12 months and after significant changes. Segmentation every 12 months, or every six months for service providers.

Summaries of the primary sources as of September 2026: the FFIEC IT Examination Handbook, 12 CFR 364 Appendix B and the matching OCC and Federal Reserve appendices, 12 CFR 748 Appendix A, 23 NYCRR 500.5, 16 CFR 314.4 and 314.6, and PCI DSS v4.0.1. Confirm your own obligations with counsel or your examiner.

How it runs

Typical engagements

Illustrative scopes for this industry, written to show what a test covers and what you walk away with. They are not client stories; our anonymized engagements are on the case studies page.

Typical engagement

Community bank ahead of its information technology examination

A community bank with a handful of branches wants independent testing evidence before its next examination. We run an external test of the perimeter and remote access, an internal test from a branch workstation toward the core connection and the domain, and a phishing campaign across staff. The report ties each finding to the bank’s risk assessment, and the attestation letter goes into the exam file alongside the retest results.

Typical engagement

Credit union after a digital banking platform migration

A credit union has moved members to a new vendor-hosted online and mobile banking platform and wants its own assurance rather than the vendor’s. We obtain the vendor’s testing authorization, test the member portal and mobile apps with accounts in every role, and focus on enrollment, reset, and transfer flows. The credit union receives findings the vendor is obliged to fix and evidence for its examiners.

Typical engagement

New York trust company completing its annual NYDFS certification

A New York-chartered trust company needs the section 500.5 testing done before its annual certification of compliance. We scope external and internal testing to the systems that hold nonpublic information, coordinate windows with the operations team, and deliver a report structured around the regulation’s requirements with an attestation letter the compliance officer can reference in the certification.

FAQ

What banks and credit unions ask

01Do examiners require a penetration test?

The FFIEC handbooks treat penetration testing and vulnerability assessment as expected components of an information security program, and examiners ask for the results. The FTC Safeguards Rule makes annual penetration testing explicit for the non-bank financial institutions it covers, and NYDFS 23 NYCRR 500.5 makes it explicit for New York-regulated entities. In practice every institution we work with is asked for a recent independent test. Fintech partners you sponsor carry obligations of their own, covered in our guide to fintech penetration testing requirements.

02Does GLBA require penetration testing for banks?

Not by name, and there is no separate GLBA penetration testing mandate for banks. The Interagency Guidelines that implement GLBA call for regular tests of key controls, run or reviewed by someone independent of the people who maintain them, at a frequency set by your risk assessment. An independent penetration test is the most direct way to show that testing happened, and examiners ask for the results. The FTC’s rule for non-bank lenders goes further and names annual testing: see FTC Safeguards Rule penetration testing.

03Do credit unions follow different rules than banks?

The testing standard is the same. Federally insured credit unions follow NCUA Part 748, Appendix A, which mirrors the bank guidelines: regular tests of key controls, independent testers or reviewers, and a frequency set by the risk assessment. NCUA is an FFIEC member agency, so the same handbook applies. For member-facing apps, mobile banking app penetration testing covers the iOS and Android apps and the API behind them.

04We are a New York-chartered institution. What does NYDFS 500.5 add?

Section 500.5 requires penetration testing from inside and outside your information systems’ boundaries at least once a year, by a qualified internal or external party. It also requires automated vulnerability scans, with manual review of systems the scans do not cover, at a frequency your risk assessment sets and promptly after material system changes. The results support the annual certification of compliance. Our NYDFS cybersecurity regulation guide covers the rest of Part 500.

05Can you test our vendor-hosted online banking platform?

Yes, with the vendor’s authorization, which most digital banking providers grant through a standard testing policy. We handle the request with you, test within the vendor’s rules using accounts you control, and report findings in a form you can hand to the vendor for remediation. Testing your own instance is the only way to know how your configuration and your members’ data actually hold up.

06How much does penetration testing cost for a bank or credit union?

External network testing starts at $4,200, internal network testing at $6,000, web application testing at $5,200, and phishing campaigns at $3,600, each fixed in writing before work starts. The penetration tests include a free retest of remediated findings. A typical annual program for a community institution combines external, internal, and phishing testing and is quoted as one number. Our network penetration testing services page shows how the external and internal tests fit together.

07How do you avoid disrupting operations?

Rules of engagement are agreed with your operations and IT teams before testing begins: windows, systems to handle with care, vendor connections that are off limits, and an emergency contact. We never use denial-of-service techniques, we coordinate any testing that touches payment systems, and internal testing is delivered remotely through a device we ship so no branch has to host a tester. That is also how we serve Charlotte banks and their vendors without a travel charge, while community banks on Long Island and Westchester banks and credit unions can meet us on site.

08How often should a financial institution test?

Annually at a minimum, which is what NYDFS 500.5, the FTC Safeguards Rule, and examiner expectations line up on, and again after a core conversion, a digital banking migration, a merger, or a significant change to remote access. Vulnerability assessments run more often, usually as a quarterly or monthly vulnerability management program, and phishing is best measured on a recurring schedule rather than once.

09Do you test staff for business email compromise and wire fraud?

Yes. Phishing, voice, and text campaigns are scoped to the roles that approve payments and change account details, with pretexts that mirror real fraud attempts. The report shows who clicked, who submitted credentials, who reported, and how fast, and a red team assessment can extend the exercise to an objective such as originating a test wire. A Microsoft 365 security assessment from $4,200 reviews the tenant controls the same fraud depends on: MFA, conditional access, and mailbox forwarding rules. In person, physical penetration testing checks whether someone posing as a vendor or technician can get past a branch or back office, from $6,800 for one New York metro site.

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