Once the resilience capabilities have been developed and implemented (P1 and P2), this phase ensures the program becomes an ongoing, embedded organisational capability rather than a one-time project.
BNM’s Discussion Paper is a consultative policy document outlining high-level principles and emerging expectations for financial institutions to strengthen operational resilience. It emphasizes:
Unlike BCM Institute’s methodology (which outlines a structured planning and sustain lifecycle), BNM’s paper serves as a statement of regulatory expectations and principles rather than a step-by-step implementation guide.
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Sustain Phase Activity (BCM Institute) |
BNM Discussion Paper Direction/ Expectation |
Alignment / Key Differences |
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[P3-S1] Introduce Cultural Change Management |
BNM calls for board-level accountability and a shift in mindset where operational resilience is a core business priority rather than an IT/risk silo. |
Strong alignment. Both frameworks emphasise the need for a cultural shift away from compliance-only thinking toward proactive resilience. BCM Institute embeds change management, whereas BNM highlights cultural enablers (e.g., leadership accountability). |
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[P3-S2] Develop a Communication Strategy |
BNM implicitly expects clear communication, escalation during disruptions, and transparent reporting to stakeholders/regulators. |
Aligned in intent. BCM Institute formalises communication as a sustainable activity; BNM’s paper emphasises communication as part of governance and crisis management expectations. |
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[P3-S3] Implement Training and Awareness |
BNM underscores the importance of skills and preparedness across functions for managing operational risk and resilience (not explicitly detailed but implied by governance and operational capability expectations). |
Aligned. BCM Institute’s explicit training and awareness stage complements BNM’s high-level expectations that institutions have competent, skilled staff capable of delivering resilience outcomes. |
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[P3-S4] Provide Self-Assessment |
BNM expects ongoing self-evaluation and adaptation of frameworks (e.g., addressing gaps identified in severe-scenario testing and third-party risk exposures). |
Complementary. BCM Institute structures self-assessment as sustain activity to ensure the program remains relevant. BNM requires institutions to understand their own resilience gaps, but does not prescribe mechanisms for self-assessment. |
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[P3-S5] Conduct an Independent Quality Review |
BNM’s broad expectations include independent oversight, such as internal audit, board assurance, and external reporting, particularly with respect to resilience and systemic stability. |
Partially aligned. BCM Institute provides an audit/review mechanism that supports the governance and assurance BNM indicates, although BNM doesn’t articulate specific review steps. |
Both frameworks see governance as a continuous responsibility:
Sustaining governance focus enables institutions to consistently respond to dynamic risk environments and regulatory expectations.
Both frameworks require ongoing evaluation and improvement:
Continuous improvement assures that resilience measures remain appropriate as technology, third-party landscapes, and threat environments evolve.
Communication isn’t just crisis response; it’s a sustainment function that ensures resilience roles are understood, expectations are clear, and lessons are shared — internally and externally.
BNM reinforces that communication to regulators, stakeholders, and customers during stress events is essential to preserve trust.
A sustained communication strategy bridges internal preparedness and external confidence — a key outcome of resilience.
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BNM Emphasis |
What It Implies Beyond Sustainable Activities |
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Ecosystem-Wide Coordination |
BNM emphasises coordination across the ecosystem (vendors, infrastructure, cross-institutional interdependencies)—an expectation that extends beyond internal sustain activities to include external collaboration and data sharing. |
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Regulatory Reporting Expectations |
BNM’s consultation process implies institutions may be required to report resilience frameworks, test results, and governance evidence to regulators. BCM Institute maintains procedures for generating these artefacts, but doesn’t mandate a reporting format. |
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Systemic Impact Orientation |
BNM focuses on protecting financial system stability, not just organisational continuity — this extends the sustainability agenda into macro-resilience planning. |
If an institution uses the BCM Institute’s Sustain phase as the basis for its resilience program:
✔ Strong operational foundation: The activities in P3 cover key elements BNM expects in a mature resilience program (culture, training, assessment).
✔ Complement with ecosystem coordination: Embed processes for third-party and industry collaboration to satisfy BNM’s ecosystem resilience expectations.
✔ Embed regulatory reporting: Adapt sustain activities to include structured evidence and reporting ready for regulatory engagement.
✔ Link self-assessment with risk tolerance and test outcomes: Ensure self-assessment isn’t just a checklist but tied to BNM-style impact tolerances and scenario findings.
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Sustain Phase Outputs |
BNM Operational Resilience Expectations |
Status |
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Cultural Change Metrics |
Strong leadership, accountability mindset |
Aligned |
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Communication Plans |
Transparent stakeholder communication |
Aligned |
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Training Programs |
Competency building for operational risk |
Aligned |
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Self-Assessment Reports |
Ongoing resilience evaluation |
Aligned |
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Independent Quality Review reports |
Assurance and governance review |
Aligned |
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Regulatory Risk & Ecosystem Reporting |
Systemic resilience reporting |
Goes Beyond |
Comparison with BNM OR Paper with BCM Institute's Operational Resilience Planning Methodology |
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| C1 | C2 | C3 | C4 | C5 |
To learn more about the course and schedule, click the buttons below for the OR-300 Operational Resilience Implementer [OR-3] course and the OR-5000 Operational Resilience Expert Implementer [OR-5] course.
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If you have any questions, click to contact us. |
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