Scenario testing is a core component of operational resilience, requiring institutions such as Bank Islam Malaysia Berhad to assess their ability to remain within defined impact tolerances under severe but plausible disruptions. For CBS-3 Retail Financing Services, scenario testing evaluates end-to-end service continuity across product governance, credit processing, documentation, disbursement, servicing, collections, and reporting.
In line with expectations set out in the Bank Negara Malaysia 2025 Discussion Paper on Operational Resilience, the objective is not merely to prevent incidents, but to demonstrate the ability to respond, recover, adapt, and learn—especially where cyber and ICT risks intersect with business processes.
The table below outlines recommended scenario testing themes for each Sub-CBS, including integration with cyber and ICT risks, expected impacts, and evidence of proactive risk management actions.
|
Sub-CBS Code |
Sub-CBS |
Recommended Scenario Test Themes (Including Cyber & ICT Integration) |
Impact / Effect |
Evidence of Proactive Risk Management Action |
|
3.1 |
Product Structuring & Shariah Governance |
• Corruption of product parameter database due to cyber intrusion • Unavailability of Shariah approval documentation repository (DMS outage) • ICT system misconfiguration affecting profit rate logic |
Incorrect product terms released; Shariah non-compliance risk; regulatory breach |
• Regular access control reviews • Secure configuration management testing • Periodic Shariah compliance audits • Tested DMS backup restoration |
|
3.2 |
Customer Application Intake & Submission |
• Online financing portal outage due to DDoS attack • Malware infection at branch workstation • Data leakage of customer applications |
Application backlog, reputational damage, and data privacy breach |
• DDoS simulation testing • Endpoint detection and response (EDR) testing • Data encryption and secure transmission validation • Incident response drill records |
|
3.3 |
Credit Assessment & Approval |
• Credit scoring engine failure • Third-party CCRIS data feed disruption • Ransomware affecting credit workflow system |
Delayed approvals, inaccurate risk assessment, breach of impact tolerance |
• Third-party SLA testing • Manual fallback underwriting procedures • Segregated network architecture • Periodic ransomware recovery testing |
|
3.4 |
Financing Documentation & Legal Perfection |
• System outage during e-signature processing • Document tampering attempt • Failure of land registry integration system |
Legal unenforceability; delayed disbursement; legal risk exposure |
• Digital signature validation controls • Secure API penetration testing • Escrow and document reconciliation checks • Legal contingency procedures |
|
3.5 |
Disbursement Processing |
• Core banking disbursement module failure • Payment gateway outage • Privileged access abuse manipulating disbursement amount |
Incorrect or delayed fund release; financial loss; fraud risk |
• Segregation of duties (SoD) testing • Core banking DR simulation • Payment reconciliation testing • Privileged access monitoring logs |
|
3.6 |
Account Setup & Maintenance |
• Interface failure between financing system and core banking • Batch processing corruption • Cyberattack altering account master data |
Inaccurate balances, customer complaints, and reconciliation breaks |
• Data integrity checks • Automated reconciliation scripts • Daily exception reporting • Periodic data recovery testing |
|
3.7 |
Instalment Collection & Payment Processing |
• Payment channel outage (online banking/mobile) • Cyberattack on direct debit processing • File transmission failure with payroll deduction partners |
Missed instalments; arrears spike; customer dissatisfaction |
• Alternative payment channel activation tests • Secure file transfer validation • Collection continuity playbooks • Impact tolerance monitoring dashboard |
|
3.8 |
Profit Calculation & Statement Generation |
• Profit calculation engine misconfiguration • Statement batch job failure • Manipulation of rate tables via cyber intrusion |
Incorrect profit charges, regulatory breach, and customer disputes |
• Dual-control rate change governance • Recalculation validation testing • Audit trail reviews • Cyber access logs monitoring |
|
3.9 |
Arrears Monitoring & Early Intervention |
• Predictive analytics tool outage • Data corruption in arrears ageing report • Unauthorized access to delinquency data |
Delayed intervention, increased credit losses, and data confidentiality breach |
• Stress testing of analytics systems • Backup MIS reporting templates • Role-based access control testing • Early-warning KPI tracking |
|
3.10 |
Recovery & Collection Management |
• Case management system downtime • Ransomware locking recovery database • Third-party collection agency ICT disruption |
Collection delays, recovery loss, and customer hardship escalation |
• Third-party resilience assessment • Offline recovery procedure drills • Secure data sharing protocols • Vendor BCP testing evidence |
|
3.11 |
Customer Service & Complaint Handling |
• Call centre system outage • CRM data breach • AI chatbot malfunction providing incorrect advice |
Complaint backlog; reputational risk; regulatory escalation |
• Call centre failover test • CRM encryption validation • Crisis communication simulation • Root cause analysis documentation |
|
3.12 |
Regulatory, Risk & Shariah Reporting |
• Regulatory reporting system failure during submission deadline • Data integrity compromise in risk reporting • Cyberattack on regulatory interface portal |
Late/inaccurate reporting; regulatory sanction; governance breakdown |
• Parallel reporting validation • Independent data reconciliation testing • Regulatory submission dry-runs • Cyber resilience testing aligned to reporting calendar |
Scenario testing for CBS-3 Retail Financing Services enables Bank Islam to move beyond theoretical resilience and demonstrate practical preparedness against severe but plausible disruptions. By embedding cyber and ICT risk integration into each Sub-CBS, the institution strengthens its ability to remain within defined impact tolerances while protecting customers, upholding Shariah governance, and meeting regulatory expectations. Continuous testing, lessons learned, and adaptive improvements will ensure that retail financing operations remain sustainable, secure, and resilient in an evolving threat landscape.
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Implementing Operational Resilience for Bank Islam: Aligning with BNM and Global Best Practices |
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| CBS-3 Retail Financing Services | |||||
| CBS-3 DP | CBS-3 MD | CBS-3 MPR | CBS-3 ITo | CBS-3 SuPS | CBS-3 ST |
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