[OR] [BC] [E3] [CBS] [1] [MD] Map Dependency

CBS-1 Deposit & Account Services

Introduction

[OR] [BC] [PH] [E3] [CBS] [1] [MD] Deposit and Account Services

For Bank of Commerce, CBS-1 Deposit and Account Services should be treated as a foundational critical business service because it underpins customer onboarding, account opening, deposit booking, balance access, withdrawals, debit-card usage, digital banking access, and ongoing account servicing across branch, ATM, online, and customer support channels.

Publicly available information shows that BankCom offers personal and corporate deposit accounts, online banking, PESONet/InstaPay access, debit cards, and a nationwide branch/ATM footprint; its 2024 public financial information also indicates that deposits are a major balance sheet component.

This makes dependency mapping essential not only for operational understanding but also for identifying where disruptions in people, processes, technology, or third parties could materially affect customers and the bank’s ability to remain within regulatory tolerance for disruption.

This mapping follows the BCM Institute's view that operational resilience mapping should identify the interconnections and interdependencies among people, processes, information, technology, facilities, and third parties required to deliver a critical business service.

BSP Circular No. 1203 reinforces this by requiring Philippine banks to identify critical operations, set tolerance for disruption, map interconnections and interdependencies, assess vulnerabilities, manage third-party and public-infrastructure dependencies, and conduct continuity exercises using severe but plausible scenarios.

Table P2: Map Dependency for CBS-1

Sub-CBS Code	Sub-CBS	Dependency Type	Dependency Detail (What/ Who is involved)	Connectivity (How it connects/ interacts with the CBS or other components)
1.1	Customer Onboarding and Account Application	People	Branch sales officers, relationship managers, tellers, customer service staff, and contact centre support	First customer touchpoint for deposit acquisition; feeds customer/ application data to KYC, approval, account opening, and digital enrollment
		Process	Product explanation, application intake, document capture, consent, CIF initiation, channel onboarding workflow	Upstream to KYC/CDD and account approval; downstream to account setup, card issuance, and digital access activation
		Technology	Branch onboarding platform, customer information file (CIF), document imaging, workflow queue, CRM	Shares customer data with compliance screening, core banking, and servicing systems
		Third Party	ID authentication utilities, courier/document support, telecom/network providers	Supports document validation, communication with customers, and availability of branch/online intake channels
1.2	Customer Identification and Verification (KYC/CDD)	People	Compliance officers, AML analysts, branch staff, and onboarding approvers	Validates identity before account opening; failure blocks onboarding and may trigger escalation to compliance
		Process	Customer due diligence, sanctions/watchlist screening, beneficial ownership checks, risk classification	Required control gate before 1.3 account approval; linked to 1.15 fraud monitoring and 1.17 regulatory reporting
		Technology	KYC/AML screening engine, CIF, records repository, case management tools	Interfaces with onboarding workflow, core customer records, and alert/case investigation platforms
		Third Party	External data/screening providers, government ID verification sources	External checks strengthen customer verification and screening completeness
1.3	Account Approval and Opening	People	Branch managers, operations approvers, compliance reviewers	Authorises account creation after KYC completion; creates accountability for exceptions and approvals
		Process	Approval matrix, maker-checker controls, CIF activation, and account number generation	Connects onboarding/KYC to core banking activation and customer servicing readiness
		Technology	Core banking system, workflow engine, account master database	Creates a live account record that becomes the basis for transactions, reporting, debit card linking, and digital banking
		Third Party	None or limited third-party role beyond infrastructure/network support	Mostly internal, but relies on available communications and infrastructure to complete the approval workflow
1.4	Initial Funding and Deposit Booking	People	Tellers, branch operations staff, treasury/back-office support for clearing confirmation	Executes the first funding transaction and confirms account usability
		Process	Cash acceptance, check deposit, transaction posting, receipt issuance, and clearing treatment	Initiates monetary balance in the new account; feeds ledger, reconciliation, and balance reporting
		Technology	Teller platform, cash transaction module, core banking, and branch systems	Post the first ledger entry and update the available/ledger balance for customer access
		Third Party	Clearing networks, armoured cash/logistics where relevant	External settlement or cash support may affect the speed of fund availability
1.5	Product Setup and Account Parameter Maintenance	People	Product managers, deposit operations staff, IT application support, and authorised approvers	Maintain product codes, interest rules, fees, holds, and transaction limits used across all deposit accounts
		Process	Parameter maintenance, maker-checker review, rate updates, product change management	Incorrect setup propagates to transaction processing, fees, statements, and compliance outcomes
		Technology	Product table maintenance in core banking, rate engines, and configuration tools	Drives the behaviour of 1.6, 1.9, 1.10, 1.12, and 1.14 through system configuration
		Third Party	Limited; may include vendor-supported core banking configuration services	Changes may depend on vendor support during releases or production issues
1.6	Deposit Transactions Processing	People	Tellers, branch ops, clearing/back-office staff, customer support	Supports routine deposits, transfers, and posting events for active deposit accounts
		Process	Deposit posting, transfer processing, cut-off handling, batch settlement, transaction validation	Central transaction engine for the service; feeds balances, statements, reconciliation, and fraud monitoring
		Technology	Core banking, teller system, switch/connectivity, online and business banking platforms	Integrates branch, ATM, and digital channels into one transaction posting environment
		Third Party	Payment rails such as PESONet/InstaPay participants, telecom/network providers	External network availability affects transaction completion, acknowledgements, and reversals
1.7	Withdrawal and Funds Access Processing	People	Tellers, branch cash custodians, ATM support staff, operations supervisors	Enables cash withdrawal and account access; disruption has immediate customer impact
		Process	Withdrawal authentication, signature/PIN validation, limit checks, cash release, override handling	Depends on account status, available balance, fraud controls, and card/channel availability
		Technology	Core banking, ATM/CRM platform, teller application, card switch, authorisation engine	Connects the account ledger to the branch and self-service withdrawal channels
		Third Party	ATM hardware/software vendors, cash replenishment/logistics, network operators	Directly affects customer cash access, especially in off-site and shared network environments
1.8	Account Servicing and Customer Maintenance	People	Branch service officers, customer care team, operations support	Handles updates to customer profile, signatures, contact details, and account instructions
		Process	Maintenance requests, document verification, record update, and exception approvals	Keeps account information current for statements, alerts, KYC refresh, and secure servicing
		Technology	CIF, CRM, document management, servicing workflow tools	Synchronises customer master data across deposit, card, and digital channels
		Third Party	Messaging providers, courier support, telecom/network	Enables customer notifications and secure delivery of servicing outputs
1.9	Interest, Fees, and Charges Processing	People	Product operations, finance, deposit operations, and IT support	Oversees rule accuracy, product profitability, and customer charging integrity
		Process	Interest accrual, capitalisation, fee charging, reversal, waiver approval, tax handling	Affects customer balances, product reporting, complaints, and regulatory disclosure accuracy
		Technology	Core banking batch engine, rate tables, fee calculators, GL interface	End-of-day and period-end processing feed statements, reconciliation, and finance reports
		Third Party	Tax/regulatory reference sources, vendor-supported batch jobs where applicable	External reference data or vendor issues can affect processing integrity
1.10	Statement, Passbook, and Balance Reporting	People	Branch staff, operations reporting team, and customer service	Delivers visibility of balances and transaction history to customers and internal teams
		Process	Statement generation, passbook updating, balance inquiry, and report distribution	Relies on accurate postings from 1.4, 1.6, 1.7, and 1.9; supports dispute handling and customer trust
		Technology	Statement engine, passbook printer, mobile/web balance inquiry, document archive	Connects core balances to branch, online, and app-based customer reporting
		Third Party	Email/SMS providers and print/mail vendors were used	Delivers statements and alerts to customers through external communications channels
1.11	Digital Account Access and Channel Integration	People	Digital banking team, IT operations, customer support, cybersecurity staff	Maintains customer access through BankCom Personal/Business platforms and app support
		Process	Enrollment, device linking, authentication, password reset, session/security controls	Connects deposit accounts to digital self-service and balance/transaction functionality
		Technology	Online banking platform, mobile app, IAM/authentication tools, API/middleware, network security controls	Enables digital viewing and transacting on deposit accounts; it depends on secure connectivity and account data synchronisation
		Third Party	Internet service providers, app distribution ecosystems, OTP/messaging providers, security certificate providers	Outage or latency can impair login, alerts, and customer access; public sources also show device-link and password controls are part of the channel design
1.12	ATM and Card-Based Access Management	People	Card operations, ATM support, branch staff, fraud operations	Supports issuance, linking, blocking, replacement, and ATM usage of deposit-linked debit cards
		Process	Card issuance, PIN handling, card-account linking, ATM transaction authorisation, hotlisting	Connects deposit accounts to ATM/POS/card-based access and withdrawal capability
		Technology	Card management system, ATM/CRM fleet, switch, authorisation platform, EMV and contactless controls	Integrates core deposit balances with card rails and self-service access channels
		Third Party	NCR or other ATM vendors, Mastercard, BancNet, ATM maintenance/logistics providers	BankCom publicly states debit cards are Mastercard- and BancNet-enabled, and that its ATM re-fleeting program uses NCR-supplied machines; these dependencies are central to account access
1.13	Account Reconciliation and Exception Handling	People	Operations control, finance, branch operations, IT support	Resolves breaks, unmatched items, suspense entries, and failed/reversed transactions
		Process	Daily reconciliation, exception investigation, break resolution, and adjustment approval	Critical control to maintain ledger integrity and support statements, complaints, and reporting
		Technology	Reconciliation engine, GL interface, exception dashboard, reporting tools	Pulls data from core banking, ATM, card, and digital systems to detect anomalies
		Third Party	Network settlement files, ATM/card schemes, payment rails	External files and settlement confirmations are necessary to reconcile interbank and card transactions
1.14	Dormancy, Holds, and Account Restrictions Management	People	Branch operations, compliance, legal, and deposit operations	Applies restrictions for dormancy, legal holds, sanctions, deceased accounts, and suspicious cases
		Process	Dormancy tagging, hold placement/removal, freeze/restrict workflows, status review	Controls whether transactions may proceed and feeds fraud, compliance, and customer servicing
		Technology	Core banking status controls, compliance case tools, servicing workflows	Interfaces with transaction authorisation, withdrawal processing, and account maintenance
		Third Party	Legal notices, court/government instructions, where applicable	External instructions can trigger or lift restrictions affecting fund access
1.15	Fraud Monitoring and Transaction Surveillance	People	Fraud analysts, AML team, cybersecurity team, and branch escalation contacts	Detects anomalous behaviour across deposit, ATM, and digital channels
		Process	Rule-based alerting, case investigation, account blocking, escalation, and customer contact	Supports immediate protection of funds and resolves disputes, reporting, and control improvements
		Technology	Fraud monitoring engine, SIEM/log analysis, transaction monitoring, case management tools	Consumes transactions from core, ATM, digital, and card systems to identify suspicious activity
		Third Party	Card networks, external fraud intelligence, telecom/SMS providers	External alert, chargeback, and customer communication dependencies support detection and containment
1.16	Complaints, Disputes, and Service Recovery	People	Customer care, branch managers, dispute resolution officers, operations support	Restores service confidence when balances, fees, withdrawals, card use, or digital access are disputed
		Process	Complaint intake, investigation, service recovery, fee reversal, dispute resolution, root cause analysis	Depends on records from statements, fraud cases, ATM logs, and transaction histories
		Technology	CRM, complaint case management, call centre tools, transaction history retrieval	Connects customer-reported issues with operational evidence from multiple upstream systems
		Third Party	ATM/card network partners, merchants/acquirers, message providers	Required for dispute evidence, external reversals, or interbank/card-related complaint resolution
1.17	Regulatory Reporting and Compliance Monitoring	People	Compliance officers, finance/regulatory reporting staff, operations management, internal audit	Ensures deposit service operations remain compliant with BSP, AML, consumer, and reporting duties
		Process	Regulatory reporting, exception review, compliance attestations, breach escalation, and management reporting	Pulls data from onboarding, KYC, transactions, restrictions, fraud, complaints, and reconciliation
		Technology	Regulatory reporting tools, data warehouse, MIS, compliance dashboards	Consolidates service data for internal governance and external supervisory obligations
		Third Party	Regulators, external auditors, regtech/data vendors were used	External submissions, audits, and data dependencies influence reporting timeliness and completeness
1.18	Business Continuity and Service Recovery for Deposit Services	People	Crisis management team, business continuity coordinators, IT DR team, branch leadership, operations heads	Coordinates response when deposit services are disrupted across the branch, ATM, digital, or support functions
		Process	Incident response, invocation of BCP/DR, alternate processing, manual workarounds, communications, recovery validation	Cross-cuts all sub-CBS and governs restoration sequence to keep deposit services within tolerance
		Technology	DR site, backup systems, replicated data, recovery runbooks, communications tools	Enables restoration of core banking, ATM, digital, and reporting systems after disruption
		Third Party	Telecom/power providers, cloud or data-centre providers, ATM/network vendors, and alternate site support	BSP requires banks to assess public infrastructure and third-party dependencies and ensure continuity arrangements or alternatives for critical operations

BSP Circular No. 1203: Operational Resilience Requirements and Bank of Commerce Examples

For a Bank of Commerce, BSP Circular No. 1203 sets forth several requirements that are especially relevant to CBS-1 Deposit and Account Services.

First, the board and senior management must oversee operational resilience and receive reporting on the bank’s capability to remain within its tolerance for disruption.

In practice at BankCom, this means deposit-service resilience should be elevated beyond branch operations to board-level reporting, with metrics such as the maximum tolerable outage for account opening, deposit posting, ATM withdrawals, digital balance inquiries, and complaint turnaround.

Second, the Circular requires banks to identify critical operations, then use those identified operations to drive tolerance for disruption and mapping of interconnections and interdependencies.

For BankCom, CBS-1 would likely be treated as a critical operation because it supports deposits, customer access to funds, and transaction continuity across its branch, ATM, debit card, and digital channels.

A practical example would be defining separate tolerances for account-opening backlog, cash-withdrawal interruptions, digital login unavailability, and unreconciled deposit exceptions.

Third, BSP requires banks to identify vulnerabilities in the mapping exercise, keep the mapping up to date, and manage third-party arrangements that affect critical operations, including continuity provisions and fallback options.

For BankCom, this means the mapping should explicitly flag dependencies, including online banking availability, telecom links, card scheme connectivity, BancNet/Mastercard access, ATM fleet support, and any vendor-supported core or channel systems.

A strong example would be documenting fallback measures, such as branch over-the-counter withdrawals, manual exception booking, alternative communication scripts, or temporary in-house processing, when an external provider fails.

Fourth, the Circular states that public infrastructure dependencies such as telecommunications, transportation, and energy should be assessed, and that BCM should be integrated into the operational resilience framework.

It also requires periodic business continuity exercises over critical operations and their dependencies using severe but plausible scenarios.

For BankCom deposit services, useful scenarios would include: a core banking outage during salary-credit day; an ATM switch failure affecting card withdrawals; a cyberattack on digital banking; a telecom outage isolating branches from head office systems; or a third-party failure affecting ATM servicing or OTP delivery.

The dependency map for CBS-1 Deposit and Account Services shows that Bank of Commerce’s deposit service is not a single process but a tightly connected service chain spanning onboarding, KYC, approval, booking, transactions, withdrawals, servicing, digital access, cards, reconciliation, fraud monitoring, complaints handling, compliance, and continuity management.

The value of this map is that it exposes where operational fragility may sit: not only in core banking, but also in customer-facing staff, approval workflows, ATM and debit-card infrastructure, external payment and network connections, telecom and power availability, third-party service providers, and response-and-recovery arrangements.

For operational resilience purposes, this chapter should therefore be used as a working management tool. It gives BankCom a structured basis for identifying vulnerabilities, prioritising remediation, testing disruption scenarios, and demonstrating alignment with BSP Circular No. 1203.

In practical terms, the bank should next use this dependency map to identify single points of failure, assign ownership for each dependency, set measurable tolerance levels, and test whether CBS-1 can continue or recover quickly enough to avoid intolerable harm to customers, the bank, and the wider financial system.

eBook 3: Starting Your OR Implementation for Bank of Commerce
CBS-1 Deposit & Account Services
CBS-1 DP	CBS-1 MD	CBS-1 MPR	CBS-1 ITo	CBS-1 SuPS	CBS-1 ST

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A Practical Guide to Operational Resilience for Bank of Commerce

[OR] [BC] [E3] [CBS] [1] [MD] Map Dependency

Operational Resilience Certified Planner-Specialist-Expert

CBS-1 Deposit & Account Services

Introduction

Table P2: Map Dependency for CBS-1

BSP Circular No. 1203: Operational Resilience Requirements and Bank of Commerce Examples

More Information About OR-5000 [OR-5] or OR-300 [OR-3]

Comments:

A Practical Guide to Operational Resilience for Bank of Commerce

[OR] [BC] [E3] [CBS] [1] [MD] Map Dependency

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Operational Resilience Certified Planner-Specialist-Expert

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Introduction

Table P2: Map Dependency for CBS-1

BSP Circular No. 1203: Operational Resilience Requirements and Bank of Commerce Examples

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More Information About OR-5000 [OR-5] or OR-300 [OR-3]

Comments:

CBS-1 Deposit & Account Services