CBS-3 Retail Financing Services
Introduction
This chapter maps the interconnections and interdependencies that support CBS-3 Retail Financing Services of Bank Islam Malaysia Berhad. In line with operational resilience principles and the 2025 BNM Discussion Paper on Operational Resilience, dependency mapping identifies the people, processes, technology, and third parties that enable each Sub-CBS to operate within defined impact tolerances.
The objective is to provide a structured view of how disruptions may propagate across systems, functions, and external partners, and to support scenario testing, recovery planning, and control enhancement.
By clearly documenting how each Sub-CBS connects to upstream inputs and downstream outputs, the bank can better assess concentration risk, single points of failure, and critical external dependencies—particularly in areas such as Shariah governance, credit decisioning systems, payment infrastructure, and regulatory reporting platforms.
Table P2: Map Dependency for CBS-3
|
Sub-CBS Code |
Sub-CBS |
Dependency Type |
Dependency Detail (What/Who is involved) |
Connectivity (How it connects/interacts with CBS or other components) |
|
3.1 |
Product Structuring & Shariah Governance |
People |
Product Development Team, Shariah Committee, Risk Management |
Defines Shariah-compliant financing structures (e.g., Murabahah, Tawarruq) that feed into system configuration and documentation templates |
|
|
|
Process |
Product approval framework, Shariah review cycle, New Product Approval (NPA) process |
Approval outputs become mandatory input before system setup and customer onboarding |
|
|
|
Technology |
Product Management System, Document Template Repository |
Configured parameters flow into the core banking and financing modules |
|
|
|
Third Party |
External Shariah advisors (if applicable) |
Independent validation influencing product rollout timeline |
|
3.2 |
Customer Application Intake & Submission |
People |
Branch staff, Sales agents, Contact Centre |
Initiates financing lifecycle; data captured for credit processing |
|
|
|
Process |
KYC/CDD onboarding, application validation checklist |
Data passed to Credit Assessment (3.3) |
|
|
|
Technology |
LOS (Loan Origination System), eKYC platform, CRM |
Interfaces with credit bureau systems and core banking |
|
|
|
Third Party |
Credit Bureau (e.g., CTOS/CCRIS), eKYC vendors |
Real-time verification feeds into risk scoring |
|
3.3 |
Credit Assessment & Approval |
People |
Credit Analysts, Approving Authority, Risk Review |
Decision authority determining approval/rejection |
|
|
|
Process |
Credit scoring, risk grading, Shariah compliance screening |
Output determines documentation and limit creation |
|
|
|
Technology |
Credit Scoring Engine, Risk Rating Models |
Integrated with LOS and Core Banking System |
|
|
|
Third Party |
External data providers (income verification, CCRIS) |
Data feeds influencing risk assessment accuracy |
|
3.4 |
Financing Documentation & Legal Perfection |
People |
Legal Team, Documentation Officers, Panel Lawyers |
Ensures enforceability of contracts |
|
|
|
Process |
Contract preparation, stamping, and charge registration |
Completed documentation required before disbursement |
|
|
|
Technology |
Document Management System (DMS), e-Signature platform |
Interfaces with LOS and imaging repository |
|
|
|
Third Party |
Panel law firms, Land Office, SSM |
External registration confirms collateral perfection |
|
3.5 |
Disbursement Processing |
People |
Operations Processing Team, Authorisers |
Execute fund release |
|
|
|
Process |
Disbursement verification, dual control authorisation |
Triggered upon documentation completion |
|
|
|
Technology |
Core Banking System (CBS), Payment Gateway, GL system |
Post entries and connect to payment rails |
|
|
|
Third Party |
Interbank payment network (e.g., RENTAS/IBG), beneficiary bank |
Funds transferred externally, where applicable |
|
3.6 |
Account Setup & Maintenance |
People |
Operations, Customer Service |
Account lifecycle management |
|
|
|
Process |
Account activation, limit updates, and the restructuring process |
Enables instalment billing and monitoring |
|
|
|
Technology |
Core Banking Financing Module |
Interfaces with the profit calculation engine |
|
|
|
Third Party |
System vendors (core banking provider) |
Platform availability directly impacts servicing |
|
3.7 |
Instalment Collection & Payment Processing |
People |
Collections Team, Branch Tellers |
Monitor and process repayments |
|
|
|
Process |
Auto-debit, standing instruction, payment reconciliation |
Feeds arrears monitoring (3.9) |
|
|
|
Technology |
Payment Switch, Core Banking, Reconciliation System |
Interfaces with external clearing systems |
|
|
|
Third Party |
FPX provider, Interbank GIRO (IBG), Payment network operators |
External settlement dependency |
|
3.8 |
Profit Calculation & Statement Generation |
People |
Finance, Product Ops |
Ensure Shariah-compliant profit computation |
|
|
|
Process |
Monthly accrual calculation, statement production |
Outputs feed regulatory and customer reporting |
|
|
|
Technology |
Profit Calculation Engine, Statement Generation System |
Draws data from core banking |
|
|
|
Third Party |
Print & mail vendors (if physical statements) |
Service level impacts customer communication |
|
3.9 |
Arrears Monitoring & Early Intervention |
People |
Collection Officers, Risk Monitoring |
Monitor delinquency thresholds |
|
|
|
Process |
Days Past Due (DPD) tracking, reminder cycle |
Escalates to Recovery (3.10) |
|
|
|
Technology |
Collection Management System, Analytics dashboards |
Receives feeds from core banking |
|
|
|
Third Party |
SMS/notification vendors |
Customer outreach channel dependency |
|
3.10 |
Recovery & Collection Management |
People |
Recovery Unit, Legal, External Agencies |
Enforcement and recovery strategy |
|
|
|
Process |
Restructuring, legal action, collateral disposal |
Linked to legal perfection documentation |
|
|
|
Technology |
Recovery Tracking System |
Updates exposure and impairment calculations |
|
|
|
Third Party |
Collection agencies, auctioneers, legal firms |
Operational reliance for recovery execution |
|
3.11 |
Customer Service & Complaint Handling |
People |
Contact Centre, Branch Service Officers |
Frontline engagement |
|
|
|
Process |
Complaint management workflow, escalation matrix |
Feedback loop to Product & Risk |
|
|
|
Technology |
CRM, Case Management System |
Integrated with account and financing data |
|
|
|
Third Party |
Ombudsman for Financial Services (OFS) |
External escalation channel |
|
3.12 |
Regulatory, Risk & Shariah Reporting |
People |
Compliance, Risk, Finance, Shariah Secretariat |
Oversight and assurance |
|
|
|
Process |
BNM regulatory submissions, Shariah reporting cycle |
Consolidates data from all Sub-CBS |
|
|
|
Technology |
Regulatory Reporting System, Data Warehouse |
Aggregates data from core banking & finance systems |
|
|
|
Third Party |
Regulator – Bank Negara Malaysia |
Mandatory submission channel; compliance dependency |
The dependency mapping for CBS-3 Retail Financing Services demonstrates that operational resilience is not confined to system availability alone but extends across governance, people capability, process integrity, and external ecosystem stability. Each Sub-CBS is interconnected, with upstream product structuring influencing downstream servicing, collections, and reporting. Technology platforms such as core banking systems and loan origination systems form central hubs, while third-party dependencies—credit bureaus, payment networks, legal firms, regulators, and service vendors—introduce concentration and contagion risks.
Consistent with regulatory expectations, this mapping enables Bank Islam Malaysia Berhad to identify critical resource dependencies, test severe but plausible disruption scenarios, and strengthen recovery strategies. Ultimately, understanding these interdependencies supports the bank’s ability to maintain retail financing services within defined impact tolerances, safeguarding customers, financial stability, and Shariah compliance obligations.

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