Establishing impact tolerances for Investment & Wealth Management services ensures that AmBank defines, in measurable terms, the maximum level of disruption it can absorb before causing intolerable harm to customers, market integrity, or regulatory obligations.
Unlike traditional recovery metrics that focus only on system restoration, impact tolerances emphasise the outcome to customers and stakeholders, helping the bank prioritise resilience where it matters most.
For CBS-5, this is especially critical because wealth products often involve market timing, fiduciary duties, suitability requirements, and handling of client assets. Clear tolerances enable AmBank to balance service availability, data integrity, and advisory continuity while meeting BNM and global operational resilience expectations.
The objective of this chapter is to translate resilience principles into practical tolerance thresholds for each sub-service.
|
Sub-CBS Code |
Sub-CBS |
MTD |
MTDL |
Customer Impact |
Regulatory Impact |
Impact Type |
Current Resilience Status |
Action Required |
|
5.1 |
Wealth Advisory & Financial Planning |
2 business days |
<4 hrs data |
Missed advisory decisions, reputational loss |
Moderate – suitability & fiduciary obligations |
Customer / Reputational |
Moderate |
Enhance remote advisory capability & CRM redundancy |
|
5.2 |
Unit Trust & Fund Distribution |
1 business day |
<1 hr |
Inability to transact, NAV timing issues |
High – sales conduct & disclosure rules |
Financial / Regulatory |
Moderate |
Strengthen channel redundancy & cut-off controls |
|
5.3 |
Fixed Income & Direct Bond/Sukuk Investments |
Same day (market hours) |
Near-zero |
Pricing & execution risk |
High – market conduct & Shariah compliance (for Sukuk) |
Financial / Regulatory |
Developing |
Improve real-time trade capture backup |
|
5.4 |
Dual Currency & Structured Products |
<4 hrs |
Near-zero |
Mispricing & loss exposure |
High – product governance rules |
Financial |
Developing |
Secondary pricing source & approval fallback |
|
5.5 |
Equities & Capital Markets Services |
<2 hrs (market hours) |
Near-zero |
Failed or delayed trades |
High – exchange & conduct rules |
Financial / Market |
Strong |
Periodic stress-test of trading continuity |
|
5.6 |
Private Banking & HNW Solutions |
1 business day |
<2 hrs |
Relationship & trust impact |
Moderate – fiduciary duty |
Reputational / Customer |
Moderate |
Dedicated RM backup & secure remote access |
|
5.7 |
Bancassurance & Wealth Protection |
1–2 business days |
<4 hrs |
Policy issuance delays |
Moderate – disclosure & suitability |
Customer / Regulatory |
Moderate |
Integrate insurer BCP coordination |
|
5.8 |
Estate & Legacy Planning (Will/Wasiat) |
3 business days |
<24 hrs |
Client dissatisfaction, low immediacy risk |
Low–Moderate – legal documentation accuracy |
Reputational / Legal |
Developing |
Secure document vault redundancy |
|
5.9 |
Client Reporting & Compliance |
1 business day |
<1 hr |
Reduced transparency to clients |
High – reporting obligations |
Regulatory / Reputational |
Moderate |
Automate report regeneration & backup data feeds |
Legend (example interpretation):
Defining impact tolerances for CBS-5 provides AmBank with a practical benchmark for how much disruption can be absorbed before stakeholders experience unacceptable harm. These tolerances turn resilience from a theoretical concept into measurable limits that guide investment decisions, scenario testing, and recovery prioritisation. They also encourage cross-functional alignment between business, risk, IT, and compliance teams.
Going forward, impact tolerances should be validated through scenario testing, market disruption simulations, and third-party failure exercises. As AmBank’s wealth portfolio and digital capabilities grow, tolerances may need periodic recalibration to reflect evolving customer expectations and regulatory scrutiny. When embedded into governance and testing cycles, these tolerances become a strategic tool that strengthens trust, stability, and long-term competitiveness in the wealth management space.
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