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

CBS-1 Deposit & Account Services

Introduction

For EastWest Banking Corporation, mapping dependencies for CBS-1 Deposit and Account Services helps show how deposit services are actually delivered end-to-end across branch stores, ATMs, online and mobile banking, customer service, core banking, operations support, and external providers.

EastWest publicly states that it serves consumer and middle-market customers through a broad network of stores, ATMs, internet banking, mobile banking, phone banking, and customer service, and that it continues to strengthen its information technology and operational processes.

In the context of operational resilience, the BCM Institute explains that dependency mapping should identify the interconnections and interdependencies among people, processes, information, technology, facilities, and third parties that support a critical business service.

BSP Circular No. 1203 requires Philippine banks and other BSFIs to identify critical operations, set tolerances for disruption, and map the interconnections and interdependencies needed to keep those operations running during disruptions.

The Circular also states that mapping should be end-to-end, should identify key resources such as people, processes, technology, information, facilities, and third-party arrangements, and should highlight vulnerability points, stress points, and dependencies on public infrastructure and service providers.

These regulatory expectations are reflected in the dependency mapping below.

Mapping basis: The table below is a practical, institution-tailored dependency map built from the user-provided Sub-CBS structure, the BCM Institute’s mapping approach, BSP Circular No. 1203, and EastWest’s publicly disclosed branch, ATM, online, mobile, debit card, and core banking context.

Public information indicates EastWest operates a large store and ATM network, offers online and mobile banking, issues debit cards linked to deposit accounts, and has upgraded its core banking platform to Temenos T24.

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, customer service associates, relationship managers, and contact centre staff	Frontline personnel initiate the deposit lifecycle by capturing customer data, explaining product options, and routing applications to KYC, approval, and account setup.
		Process	Account opening workflow, form completion, product suitability checks, document collection	Feeds directly into KYC/CDD, account approval, initial funding, and debit-card or digital-channel enrollment.
		Technology	Branch onboarding tools, document capture/scanning, CRM/front-end application platform, core banking interface	Captured applicant data must pass from front-end channels into verification systems and the core deposit-account setup environment.
		Third Party	ID validation utilities, courier/document services, telecom/network providers	Supports remote communications, possible external identity verification, and movement of physical records where needed.
1.2	Customer Identification and Verification (KYC/CDD)	People	Compliance officers, branch operations staff, AML investigators, and onboarding reviewers	Validate identity, beneficial ownership where applicable, and customer risk profile before account approval.
		Process	KYC/CDD, sanctions screening, watchlist screening, AML risk classification, customer due diligence escalation	Acts as a control gate between application intake and account approval; failed or pending KYC stops downstream onboarding.
		Technology	AML screening engine, customer information file, document repository, case management tools	Connects customer records to screening results and exception workflows before an account can be opened or funded.
		Third Party	Sanctions/watchlist data providers, credit/identity data sources, outsourced screening support, if used	External data sources enrich due diligence and support regulatory compliance controls.
1.3	Account Approval and Opening	People	Branch approvers, operations control staff, compliance reviewers, product operations team	Authorise account creation after satisfactory onboarding and KYC completion.
		Process	Maker-checker approval, account number generation, CIF linking, and account status activation	Converts a pending customer record into an active deposit account, triggering downstream funding and service enrollment.
		Technology	Core banking platform, approval workflow engine, customer master database	Creates the official account record in the core deposit environment and links it to customer profiles and product rules.
		Third Party	Network and data-centre providers, managed infrastructure partners	Availability of hosting and network services is essential for real-time account creation.
1.4	Initial Funding and Deposit Booking	People	Tellers, branch cash custodians, operations staff, treasury/liquidity support	Receive opening deposits via cash, check, transfer, or remittance-linked credit.
		Process	Cash receipt, check acceptance, funds posting, hold-code application, transaction balancing	Connects account opening to ledger activation and available balance creation, while handling holds and clearing conditions.
		Technology	Teller platform, core deposit ledger, cash transaction systems, clearing interface	Post opening funds to the new account and update balances visible to the branch, ATM, and digital channels.
		Third Party	Clearing networks, armoured cash/logistics providers, correspondent/remittance partners	External schemes or service providers may support non-cash funding, clearing, and branch cash operations.
1.5	Product Terms Setup and Account Parameter Maintenance	People	Product management, deposit operations, branch operations control, and IT application support	Maintain account rules, including interest basis, fees, minimum balances, dormancy rules, and channel entitlements.
		Process	Product configuration, parameter maintenance, change control, and authorisation of updates	Parameter changes affect transaction posting, fee charging, statement output, dormancy treatment, and reporting.
		Technology	Core banking parameter tables, product catalogue tools, and a change-management platform	Central rule settings feed all dependent processes and channels across the deposit service chain.
		Third Party	Vendor support for core banking/application maintenance	External support may be needed for complex configuration, patching, or controlled release changes.
1.6	Deposit Transactions Processing	People	Tellers, branch operations, payments/operations staff, channel support teams	Execute deposits, internal transfers, check deposits, and account credits.
		Process	Transaction validation, posting, settlement, reversal handling, and cutoff processing	High-volume processing supports the day-to-day delivery of the deposit service and feeds reconciliation and reporting.
		Technology	Core banking, teller system, online/mobile transaction engines, API/middleware	Must synchronise transaction posting across store, ATM, and digital channels to maintain accurate balances.
		Third Party	Payment rails, switch/network providers, telecom, utility providers	External connectivity affects transaction acceptance, authorisation, and end-user service continuity.
1.7	Withdrawal and Funds Access Processing	People	Tellers, branch cash handlers, ATM support staff, fraud/risk analysts	Support withdrawals over-the-counter, through ATMs, and via debit-enabled access channels.
		Process	Balance check, hold/freeze validation, authorisation, cash disbursement, and daily-limit enforcement	Connects account balances and restrictions to customer access to funds; directly dependent on real-time ledger integrity.
		Technology	ATM/POS switch, core banking, debit-card authorisation tools, and branch teller system	Uses the account ledger and card controls to determine whether funds can be released.
		Third Party	ATM switch/scheme providers, cash replenishment vendors, telecom/power providers	External networks and infrastructure are critical to uninterrupted card-based and ATM-based access.
1.8	Account Servicing and Customer Maintenance	People	Branch service staff, call centre agents, operations support, customer-care teams	Handle profile updates, address changes, replacement requests, account inquiries, and service requests.
		Process	Maintenance request handling, data amendment, revalidation, and customer authentication	Connects ongoing account administration to fraud controls, statement delivery, card management, and compliance records.
		Technology	Customer master file, service-request systems, CRM, document management	Ensures customer data changes propagate to account, channel, and communication systems.
		Third Party	SMS/email gateways, document/courier providers	Supports customer notifications, card or document delivery, and service communication.
1.9	Interest, Fees, and Charges Processing	People	Product operations, finance, deposit operations, control/review teams	Oversee product pricing, accrual logic, fee assessment, waivers, and exception approvals.
		Process	Interest accrual, capitalisation, fee charging, tax handling, waiver or refund processing	Depends on accurate parameters, balances, transaction history, and cut-off schedules.
		Technology	Core banking batch jobs, fee engines, accounting interfaces, and MIS tools	Batch and periodic jobs feed customer balances, general ledger, statements, and reporting.
		Third Party	Tax/reporting support tools, vendor-maintained calculation modules if applicable	Some supporting logic or statutory tables may rely on updates from external vendors.
1.10	Statement, Passbook, and Balance Reporting	People	Branch staff, customer service, operations reporting teams, print/mail support staff	Provide account statements, balance confirmations, passbook updates, and account information.
		Process	Statement generation, passbook printing, e-statement distribution, and customer inquiry handling	Draws from posted ledger data and connects to servicing, complaints, compliance, and audit trails.
		Technology	Statement generation systems, core banking extract jobs, online/mobile display layers, print systems	Converts transactional data into customer-readable outputs across physical and digital channels.
		Third Party	Print-and-mail vendors, email/SMS gateways	External fulfilment may support the delivery of physical or electronic statements.
1.11	Digital Account Access and Channel Integration	People	Digital banking team, IT operations, customer support, cybersecurity personnel	Manage enrollment, access support, incident handling, and customer assistance for online/mobile services.
		Process	User enrollment, authentication, session management, transaction routing, channel support	Links deposit accounts to EastWest’s online and mobile banking services for balance inquiry and transactions.
		Technology	EastWest Online/EasyWay, mobile app, middleware/API layer, IAM/MFA services, core banking interface	Provides customer-facing digital access and depends on secure, resilient integration with the deposit ledger.
		Third Party	Telecom/internet providers, OTP/SMS providers, cloud or managed-security services, if used	External connectivity and authentication messaging are essential to uninterrupted digital access.
1.12	ATM and Card-Based Access Management	People	Card operations team, branch staff, ATM support engineers, fraud-monitoring personnel	Support card issuance, activation, hotlisting, replacement, and ATM-service continuity.
		Process	Card issuance, activation, PIN handling, ATM access control, and card status management	Directly connects deposit accounts to customer cash access and card-based transactions.
		Technology	Debit-card management systems, ATM switch, ATM terminals, core banking, card authorisation tools	EastWest states debit cards are issued with deposit accounts and activated through EastWest ATMs, making these systems core dependencies.
		Third Party	Card scheme providers, ATM hardware/service vendors, cash-in-transit providers	External providers support authorisation, hardware maintenance, and ATM cash availability.
1.13	Account Reconciliation and Exception Handling	People	Operations control, finance, branch operations, recon analysts, internal control teams	Investigate breaks, posting mismatches, suspense items, and unbalanced cash or ledger positions.
		Process	Daily reconciliation, suspense management, exception resolution, and adjustment approval	Ensures transaction integrity across core banking, channels, settlement feeds, and general ledger.
		Technology	Reconciliation engines, exception dashboards, ledger extracts, GL interfaces	Identifies and resolves breaks that could otherwise affect balances, statements, and customer access.
		Third Party	Settlement operators, external clearing partners, and managed reconciliation tools	External breaks or delayed files can create unresolved exceptions that affect the integrity of deposit services.
1.14	Dormancy, Holds, Restrictions, and Account Control Administration	People	Deposit operations, compliance, branch operations, legal support, fraud-control teams	Manage dormant status, account holds, garnishments, freezes, deceased-account-controls, and restrictions.
		Process	Dormancy tagging, reactivation, hold placement/removal, legal order handling, restriction review	Controls customer access, withdrawal eligibility, and transaction routing based on risk, legal, or regulatory triggers.
		Technology	Core banking status codes, workflow tools, legal/compliance case logs	Restriction flags must flow accurately to the teller, ATM, card, and digital channels to prevent unauthorised access.
		Third Party	Courts/regulators/law enforcement interfaces, where applicable, notification vendors	External instructions or notices may trigger status changes or required disclosures.
1.15	Fraud Monitoring and Transaction Surveillance for Deposit Accounts	People	Fraud analysts, AML investigators, cybersecurity personnel, and branch escalation points	Detect suspicious account behaviour, unauthorised access, mule activity, or unusual cash/card/digital patterns.
		Process	Transaction monitoring, alert review, case escalation, hotlisting/freezing, suspicious-activity referral	Connects to withdrawals, digital access, card management, complaints, and regulatory reporting.
		Technology	Fraud monitoring tools, AML surveillance, card-monitoring systems, SIEM/security monitoring	Requires real-time or near-real-time ingestion of deposit, channel, and access events to act before losses escalate.
		Third Party	Fraud-data providers, card-network alerts, and managed security services, if used	External intelligence and monitoring feeds strengthen detection and response capability.
1.16	Complaints, Disputes, and Service Recovery	People	Contact centre, branch managers, dispute-resolution teams, operations support, customer-experience teams	Handle failed transactions, card disputes, service errors, delayed credits, and customer remediation.
		Process	Complaint intake, investigation, root-cause analysis, refund/reversal, customer communication	Receives inputs from all other Sub-CBS processes and feeds incident management, control improvement, and regulatory reporting.
		Technology	Case-management system, call-centre platform, CRM, transaction history tools	Requires access to customer records, transaction logs, and exception data to support timely resolution.
		Third Party	Ombudsman/regulatory channels, card-scheme dispute processes, courier/communication vendors	External schemes and service channels may be involved in dispute evidence, response, and reimbursement handling.
1.17	Regulatory Reporting and Compliance Monitoring	People	Compliance, regulatory reporting team, finance, operations control, senior management	Monitor adherence to deposit, AML, consumer protection, and operational resilience obligations.
		Process	Report compilation, control attestations, exception tracking, compliance review, and management escalation	Uses data from onboarding, monitoring, reconciliation, incidents, and complaints to support regulatory visibility.
		Technology	MIS/reporting tools, regulatory data marts, case-management systems, audit trails	Consolidates operational and customer-impact data for compliance reporting and oversight.
		Third Party	RegTech/reporting support tools, external auditors, compliance data vendors	May support specialised reporting, validation, or independent review requirements.
1.18	Incident Response, Business Continuity, and Recovery	People	Incident commanders, IT recovery teams, business continuity coordinators, crisis-management team, business owners	Lead response, invoke recovery arrangements, communicate decisions, and restore priority services within tolerance.
		Process	Incident escalation, service continuity procedures, manual workarounds, disaster recovery, crisis communication	This is the resilience wrapper around all prior Sub-CBS processes and activates when disruption threatens service delivery.
		Technology	DR environment, backup systems, resilient network connectivity, monitoring/alerting platforms, cyber response tools	Supports restoration of core banking, channels, card services, reconciliation, and monitoring after disruption.
		Third Party	Alternate-site providers, telecom and power utilities, cloud/managed infrastructure providers, critical vendors	BSP expects critical third-party arrangements, public infrastructure dependencies, and BCM capabilities to support continued delivery and recovery of critical operations.

Regulatory Requirements from BSP Circular No. 1203 Reflected in this Mapping

For a Philippine bank such as EastWest, BSP Circular No. 1203 provides several direct requirements relevant to this chapter.

First, the Board is expected to approve the bank’s identified critical operations, which then drive the next steps of setting disruption tolerances and mapping interconnections and interdependencies.

Second, the mapping must be end-to-end, from the starting point of the critical operation through delivery to the client.

Third, the mapping must identify the key resources required to keep each critical operation running, including people, processes, technology, information, facilities, and third-party arrangements.

The Circular also expects banks to use mapping to identify vulnerability points, stress points, and common-resource concentrations; to understand the roles of third-party providers, including subcontracted providers; and to assess dependencies on public infrastructure such as telecommunications, transportation, and energy.

In practical terms for deposit and account services, this means EastWest should not only identify branch, ATM, online, mobile, card, and core-banking dependencies, but also understand where outages in telecom links, power, ATM switch connectivity, sanctions-screening sources, print/mail fulfillment, cloud or managed infrastructure, and outsourced service support could prevent the bank from staying within tolerance for disruption.

Another key BSP requirement is that tolerance for disruption should be tested against severe but plausible scenarios.

The Circular specifically cites examples such as the “Big One,” severe typhoons, failure of a critical third-party service provider, disturbances in payment and settlement systems, and coordinated cyberattacks or ransomware.

It also requires periodic business continuity exercises that cover identified critical operations, along with their interconnections and key dependencies.

For EastWest’s CBS-1, that means the dependency map should later be used to set impact tolerances, design scenario tests, and prioritise recovery strategies for branches, ATMs, digital banking, card access, core ledger processing, and supporting vendors.

This dependency mapping shows that CBS-1 Deposit and Account Services is not a single process but an interconnected service chain supported by frontline personnel, control functions, branch and digital processes, core banking and card systems, customer communication tools, public infrastructure, and third-party providers.

For EastWest, the breadth of its store network, ATM footprint, debit-card services, and digital banking channels means that operational resilience depends not only on internal process strength, but also on the reliability of integration points across channels and external partners.

From an operational resilience standpoint, the value of this chapter lies in providing the foundation for the next implementation steps: mapping processes and resources in greater depth, setting disruption tolerances, identifying severe but plausible scenarios, and planning for scenario testing and recovery actions.

This is fully aligned with the BCM Institute’s mapping approach and BSP Circular No. 1203, which treats dependency mapping as a practical tool for exposing weaknesses, managing concentration and third-party risks, and improving the bank’s ability to continue delivering critical operations through disruption.

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