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[OR] [LBP] [E3] [CBS] [1] [SuPS] Identify Severe but Plausible Scenarios

Written by Moh Heng Goh | Apr 2, 2026 8:40:55 AM

CBS-1 Deposit & Account Services

Introduction


For Land Bank of the Philippines (LBP), identifying Severe but Plausible Scenarios (SuPS) is a critical requirement under BSP Circular No. 1203.

These scenarios represent extreme but realistic disruptions that could threaten the delivery of CBS-1 Deposit and Account Services.

In line with the methodology described in the BCM Institute’s OR guidance, SuPS must test the bank’s ability to remain within defined impact tolerances, especially under compounded operational, cyber, and third-party failures.

This section outlines scenario design aligned with regulatory expectations, including end-to-end service disruption, cyber compromise, data integrity failures, and third-party outages, with explicit linkage to Cyber and ICT risk integration, as mandated by regulators.

Table P5: Identify Severe but Plausible Scenarios for CBS-1   

Sub-CBS Code

Sub-CBS

Severe but Plausible Scenario

Impact / Effect

Proactive Risk Management Action

Link to Integration of Cyber and ICT Risks

1.1

Customer Onboarding and Account Application

Prolonged outage of onboarding systems due to cloud service provider failure

Inability to onboard customers; revenue and reputational loss

Multi-channel onboarding fallback; offline forms; alternate cloud region

Cloud resilience, third-party ICT dependency risk

1.2

Customer Identification and Verification

National ID verification API unavailable due to cyberattack

Delayed KYC; regulatory non-compliance risk

Alternative ID verification methods; cached verification protocols

API security, identity system cyber resilience

1.3

Account Approval and Opening

Internal workflow system compromised by ransomware

Halt in account approvals; operational backlog

Segregated approval systems; rapid system isolation and recovery

Endpoint security, ransomware defence

1.4

Initial Funding and Deposit Booking

Core banking system data corruption during peak transactions

Incorrect balances; financial loss exposure

Real-time reconciliation; backup restoration procedures

Data integrity controls, database resilience

1.5

Product Terms Setup and Maintenance

Misconfiguration due to system patch failure

Incorrect interest/fees applied to accounts

Automated validation checks; configuration rollback capability

Change management, patch governance

1.6

Deposit Transactions Processing

Distributed Denial-of-Service (DDoS) attack on transaction systems

Transaction delays/failures; customer dissatisfaction

DDoS protection; traffic rerouting; load balancing

Network security, availability protection

1.7

Withdrawal and Funds Access Processing

ATM network outage due to telecom provider failure

Customers unable to access funds

Multi-network ATM routing; branch cash contingency plans

Telecom dependency risk, network redundancy

1.8

Account Servicing and Maintenance

CRM system outage caused by system upgrade failure

Inability to update customer records; service delays

Rollback procedures; manual servicing processes

Application resilience, release management

1.9

Interest, Fees, Charges Processing

Batch processing failure due to system overload

Incorrect financial postings; reconciliation issues

Parallel batch processing; monitoring thresholds

System capacity management, processing resilience

1.10

Statement and Balance Reporting

Data extraction failure due to a reporting system bug

Customers receive incorrect/missing statements

Independent reporting validation; secondary reporting systems

Data pipeline integrity, reporting system resilience

1.11

Digital Account Access Enablement

Mobile banking app compromised by malware injection

Unauthorised access risk; service suspension

App security testing, forced updates, and MFA enforcement

Mobile app security, authentication controls

1.12

ATM and Card-Based Access Management

The card management system was breached, leading to card cloning

Fraudulent withdrawals; customer trust erosion

Card blocking automation; fraud monitoring systems

Card security, fraud analytics systems

1.13

Account Reconciliation and Exception Handling

Failure of the reconciliation engine due to a data mismatch

Undetected financial discrepancies

Automated reconciliation alerts; manual override procedures

Data validation, reconciliation system resilience

1.14

Dormancy, Holds, Restrictions Management

Unauthorised lifting of account restrictions due to an access control breach

Fraudulent access to restricted funds

Strong access controls, audit trails; periodic reviews

Identity access management (IAM), insider threat control

1.15

Fraud Monitoring and Surveillance

AI fraud detection system failed during a cyber incident

Increased fraud losses due to undetected anomalies

Backup rule-based monitoring; real-time alerts escalation

AI system resilience, cyber incident integration

1.16

Complaints, Disputes, Service Recovery

Contact centre outage due to cyberattack

Inability to handle complaints; regulatory breaches

Alternate contact channels; crisis communication plans

Communication system resilience, cyber recovery

1.17

Regulatory Reporting and Compliance Support

Regulatory reporting system unavailable during submission deadline

Non-compliance penalties; supervisory action

Pre-submission validation; backup reporting channels

RegTech system resilience, compliance, and data protection

1.18

Business Continuity and Recovery

Major disaster affecting primary data center (e.g., flood, fire)

Full service disruption; breach of impact tolerances

DR site activation; regular BCP testing; scenario exercises

DR infrastructure, ICT recovery capability

 

The identification of Severe but Plausible Scenarios for CBS-1 Deposit and Account Services enables the Land Bank of the Philippines to move beyond traditional risk assessment into forward-looking resilience testing, as required by BSP Circular No. 1203.

These scenarios demonstrate how operational, cyber, and third-party risks can converge to disrupt critical services and must therefore be tested holistically.

By embedding proactive risk management actions and explicitly linking each scenario to Cyber and ICT risk integration, LBP ensures that resilience capabilities are not only documented but operationalised.

This approach strengthens the bank’s ability to remain within defined impact tolerances, maintain customer trust, and meet regulatory expectations even under extreme but plausible conditions.

 

Strengthening Operational Resilience in Land Bank of the Philippines: A Practical Implementation Guide

eBook 3: Starting Your OR Implementation
CBS-1 Deposit & Account Services
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