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Resilience by Design: Kenanga Investment Bank’s Operational Resilience Journey
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[OR] [KIB] [E3] [CBS] [2] [ITo] Establish Impact Tolerances

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In the landscape of modern banking, the ability to withstand operational disruptions is crucial for maintaining financial stability, client trust, and regulatory compliance. CBS 2 – Clearing & Settlement Services is a core function of Kenanga Investment Bank, responsible for ensuring the accurate and timely processing of trades, margin requirements, settlements, reconciliations, corporate actions, and reporting obligations.

Given its criticality, even a temporary disruption can have significant financial, regulatory, and reputational consequences.

This chapter focuses on establishing impact tolerance for CBS 2, defining the acceptable level of disruption in terms of time, data loss, and downstream effects. By setting these thresholds, the bank can proactively design operational resilience measures, allocate resources effectively, and ensure continuity under adverse scenarios.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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Introduction

[OR] [KIB] [E3] [CBS] [2] [ITo] Establish Impact Tolerances

In the landscape of modern banking, the ability to withstand operational disruptions is crucial for maintaining financial stability, client trust, and regulatory compliance. CBS 2 – Clearing & Settlement Services is a core function of Kenanga Investment Bank, responsible for ensuring the accurate and timely processing of trades, margin requirements, settlements, reconciliations, corporate actions, and reporting obligations.

Given its criticality, even a temporary disruption can have significant financial, regulatory, and reputational consequences.

This chapter focuses on establishing impact tolerance for CBS 2, defining the acceptable level of disruption in terms of time, data loss, and downstream effects. By setting these thresholds, the bank can proactively design operational resilience measures, allocate resources effectively, and ensure continuity under adverse scenarios.

Purpose of the Chapter

The purpose of this chapter is to guide readers through the rationale and methodology for determining Maximum Tolerable Downtime (MTD) and Maximum Tolerable Data Loss (MTDL) for each detailed process of CBS 2. Establishing impact tolerances:

  • Helps quantify the risk exposure for each sub-process.
  • Ensures regulatory expectations under operational resilience frameworks are met.
  • Provides clarity on potential customers and market impacts if a disruption occurs.
  • Serves as a benchmark for ongoing resilience improvements, testing, and monitoring.

Banner [Table] [OR] [E3] Establish Impact Tolerance

Table P4: Establish Impact Tolerance for CBS-2

Sub-CBS Code

Sub-CBS

MTD

MTDL

Customer Impact

Regulatory Impact

Impact Type

Current Resilience Status

Action Required

2.1

Trade Capture & Validation

2 hours

15 mins

High: Delayed trade processing

High: Regulatory reporting delays

Financial & Operational

Moderate: Automated validation in place

Enhance monitoring; implement backup trade capture

2.2

Clearing Instructions & Netting

4 hours

30 mins

High: Disruption in netting & settlements

High: Potential regulatory breaches

Financial

Moderate: Netting system resilient

Introduce parallel netting checks

2.3

Margin & Collateral Management

2 hours

15 mins

High: Margin calls delayed

High: Non-compliance with BNM requirements

Financial

Moderate

Review collateral workflow; add redundancy

2.4

Settlement Execution

1 hour

5 mins

Very High: Missed settlements impact liquidity

Very High: BNM settlement reporting

Financial

High: Automated settlement engine

Conduct regular settlement drills

2.5

Funds & Securities Reconciliation

6 hours

1 hour

Medium: Late reconciliations

Medium: Reporting inconsistencies

Operational

Moderate

Strengthen reconciliation automation

2.6

Corporate Actions Processing

12 hours

2 hours

Medium: Delays in corporate actions

Medium: Regulatory notifications affected

Operational

Low

Implement corporate actions monitoring system

2.7

Exception & Fail Management

1 hour

5 mins

High: Unresolved trade exceptions

High: Regulatory breach if fails not reported

Operational & Compliance

Moderate

Enhance exception handling protocols

2.8

Regulatory & Financial Reporting

24 hours

1 hour

High: Late reports

High: Non-compliance with BNM

Compliance

Moderate

Automate reporting; schedule alerts for deadlines

2.9

Client & Counterparty Communication

2 hours

N/A

High: Delays in notifications

Medium: Client complaints

Reputational

Moderate

Implement communication redundancy and escalation

2.10

Technology, Controls & Monitoring

30 mins

N/A

High: Disruption in monitoring

High: Could amplify operational risk

Operational

Moderate

Upgrade monitoring tools; introduce failover controls

Note: MTD and MTDL thresholds are indicative and aligned with operational resilience principles outlined in the 2025 BNM Discussion Paper.

 

Banner [Summing] [OR] [E3] Establish Impact Tolerance

Setting impact tolerances for CBS 2 Clearing & Settlement Services provides a clear framework for operational resilience, defining how long and to what extent the bank can tolerate disruptions without causing severe financial, regulatory, or reputational damage.

By identifying the MTD, MTDL, and potential impact for each sub-process, Kenanga Investment Bank can prioritise investments in redundancy, automation, and monitoring, ensuring robust continuity plans are in place.

Continuous review and testing of these tolerances will further strengthen the bank’s readiness to respond to adverse events, aligning operational resilience strategies with regulatory expectations and client trust.

Resilience by Design: Kenanga Investment Bank’s Operational Resilience Journey

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