[OR] [AmB] [E3] [CBS] [2] [ITo] Establish Impact Tolerances

Written by Moh Heng Goh | Jan 29, 2026 2:15:36 AM

CBS-2 Payment Processing & Settlement

Establishing appropriate impact tolerances is a foundational requirement of operational resilience, ensuring that AmBank can continue to deliver its critical payment services within acceptable limits during severe but plausible disruptions.

For CBS-2 Payment Processing & Settlement, impact tolerances define the maximum level of disruption the bank can tolerate before causing intolerable harm to customers, threatening financial stability, or breaching regulatory obligations.

This chapter applies the principles of impact tolerance by assessing each Sub-CBS against key metrics such as Maximum Tolerable Downtime (MTD), Maximum Tolerable Data Loss (MTDL), customer and regulatory impact, and overall resilience posture.

The outcome supports informed decision-making on prioritisation, investment, and remediation to ensure that payment services remain reliable, compliant, and trusted across the Malaysian financial ecosystem.

Table P4: Establish Impact Tolerance for CBS-2

Sub-CBS Code	Sub-CBS	Maximum Tolerable Downtime (MTD)	Maximum Tolerable Data Loss (MTDL)	Customer Impact	Regulatory Impact	Impact Type	Current Resilience Status	Action Required
2.1	Payment Initiation & Capture	≤ 1 hour	Near-zero (≤ 5 minutes)	High – Customers unable to initiate payments; business disruption	High – Breach of service availability expectations	Financial / Reputational	Moderate	Strengthen system redundancy and front-end failover
2.2	Authorisation & Verification	≤ 30 minutes	Zero data loss	High – Payment failures and transaction rejections	High Risk of fraud and non-compliance	Financial / Regulatory	Moderate	Enhance real-time monitoring and secondary authorisation paths
2.3	Clearing & Message Exchange	≤ 2 hours	≤ 15 minutes	High – Delayed interbank payments	High – Breach of clearing house rules (e.g., RENTAS, DuitNow)	Systemic / Regulatory	Moderate	Improve interface resilience by clearing networks
2.4	Settlement Execution	≤ 2 hours	Zero data loss	Very High – Funds not received or credited	Very High – Settlement finality and liquidity risk	Financial Stability / Regulatory	Low–Moderate	Implement enhanced liquidity buffers and automated recovery
2.5	Reconciliation & Exception Handling	≤ 24 hours	≤ 1 hour	Medium – Delayed issue resolution	Medium – Audit and control weaknesses	Operational / Financial	Moderate	Increase automation and staffing surge capacity
2.6	Fees, Charges & Accounting Posting	≤ 24 hours	≤ 1 hour	Medium – Incorrect balances or delayed postings	Medium – Financial reporting inaccuracies	Financial / Reputational	Moderate	Strengthen batch controls and reconciliation checks
2.7	Reporting & Regulatory Compliance	≤ 48 hours	≤ 24 hours	Low (indirect)	Very High – Breach of BNM regulatory requirements	Regulatory / Legal	Moderate	Enhance reporting contingency procedures
2.8	Customer Notification & Statement Updating	≤ 24 hours	≤ 1 hour	Medium – Reduced transparency and trust	Low–Medium – Customer disclosure obligations	Reputational / Conduct	High	Periodic testing of notification channels and backups

By defining and applying impact tolerances across all Sub-CBS components of Payment Processing & Settlement, AmBank gains a clear understanding of where disruption becomes intolerable and where resilience investments must be prioritised. This structured approach ensures alignment with regulatory expectations, particularly in safeguarding settlement finality, data integrity, and customer trust.

The impact tolerance assessment also provides a practical foundation for subsequent operational resilience activities, including scenario testing, dependency mapping, and remediation planning. Ultimately, establishing and maintaining these tolerances enables AmBank to respond decisively to disruptions, minimise harm, and uphold confidence in its payment services under all operating conditions.

Operational Resilience Framework: A Case Study of AmBank Malaysia
eBook 3: Starting Your OR Implementation
CBS-2 Payment Processing & Settlement
CBS-2 DP	CBS-2 MD	CBS-2 MPR	CBS-2 ITo	CBS-2 SuPS	CBS-2 ST

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