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CBS-1 Customer Deposit and Account Access Services
Introduction
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CBS-1 Customer Deposit and Account Access Services represents a fundamental customer-facing banking service through which customers maintain, access, and manage funds held with MBSB.
From an Operational Resilience perspective, the service needs to be considered as an end-to-end customer outcome rather than as a single business function, system, department, or delivery channel.
This approach is consistent with the emerging direction described in Bank Negara Malaysia's 2025 Operational Resilience Discussion Paper, which emphasises preserving the continuity of critical operations and services and developing visibility over the internal and external dependencies required to deliver them.
BNM specifically identifies people, processes, data, technology, facilities, business units, and external providers as components through which disruptions may propagate.
BNM also highlights the importance of uninterrupted access to financial services, which affects consumers' ability to access their funds. Disruption to such services can have an immediate impact on customers and potentially affect confidence in the financial institution.
For MBSB, identifying the detailed processes supporting CBS-1 is therefore an important first step in developing an end-to-end view of the service.
Purpose of Decomposing CBS-1
A high-level Critical Business Service describes what MBSB needs to continue delivering to its customers. It does not, by itself, provide sufficient operational detail to identify how the service is delivered or where vulnerabilities may exist.
CBS-1 is therefore decomposed into a series of operationally meaningful Sub-Critical Business Services (Sub-CBS).
Each Sub-CBS represents a distinct process or process grouping necessary to support the customer outcome associated with deposit and account access.
The objective is not to document every procedural task performed by employees or every function executed by a banking application.
Instead, the decomposition establishes an appropriate level of granularity for subsequent Operational Resilience analysis.
This is particularly relevant because BNM's Discussion Paper raises the need for financial institutions to determine an appropriate level of mapping granularity that supports practical comparison, consolidation, and an end-to-end view.
For MBSB, the Sub-CBS catalogue will subsequently support:
- mapping of internal and external dependencies;
- identification of the people, technology, information, facilities, and third parties supporting CBS-1;
- identification of concentration risks and potential points of failure;
- assessment of customer and operational impacts arising from disruption;
- establishment of impact tolerances;
- identification of severe but plausible disruption scenarios;
- scenario testing; and
- identification and prioritisation of resilience improvements.
The relationship can therefore be expressed as:
CBS-1 Customer Deposit and Account Access Services
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End-to-End View of CBS-1
For this implementation guide, CBS-1 begins with the establishment and maintenance of an eligible customer deposit account and extends through the customer's ability to access account information and funds, maintain account instructions, and receive appropriate support where normal account access is impaired.
The proposed decomposition deliberately separates business processes from the underlying resources used to perform them.
For example, a core banking platform, mobile application, branch, telecommunications network, database, employee, or third-party technology provider is not itself a Sub-CBS.
These are resources or dependencies that should subsequently be mapped to the relevant Sub-CBS.
The following Sub-CBS catalogue provides the proposed end-to-end process structure for MBSB.
Proposed Sub-CBS Catalogue for CBS-1
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Table P1: Detailed Processes for CBS-1
|
Sub-CBS Code |
Name of Sub-CBS |
Description of Sub-CBS |
|
CBS-1.1 |
Deposit Account Establishment and Activation |
Covers the establishment and activation of customer deposit accounts so that customers can commence using the account and accessing deposited funds. Principal activities include receiving account-opening information, completing required customer and account validations, establishing the account record, assigning the appropriate account status and features, and activating the account for permitted banking services. |
|
CBS-1.2 |
Customer and Account Information Maintenance |
Maintains the customer and account information required for continued access to deposit accounts. Activities include processing authorised changes to customer particulars, contact information, account instructions, operating mandates and other account-related records. Accurate maintenance is important because incorrect or unavailable account information could restrict legitimate customer access or interfere with transaction processing. |
|
CBS-1.3 |
Account Status and Access Administration |
Manages the operational status of deposit accounts and determines whether normal access can be provided. Activities include administering account status changes, access restrictions, holds, freezes, dormancy-related conditions and subsequent reactivation or reinstatement where authorised. The process supports the controlled availability of customer accounts while ensuring that restrictions are correctly applied and removed. |
|
CBS-1.4 |
Deposit Receipt and Account Credit Processing |
Supports the receipt, validation and posting of eligible deposits or incoming credits to customer deposit accounts. The process ensures that accepted funds are accurately reflected in customer balances and become available in accordance with applicable processing conditions. Activities include validating incoming deposit information, applying credits, handling exceptions and ensuring appropriate account balance updates. |
|
CBS-1.5 |
Account Balance and Transaction Record Processing |
Maintains accurate balances and transaction records required for customers to determine the position of their deposit accounts. Activities include updating account balances following completed transactions, maintaining transaction histories, applying relevant value dates and ensuring that account information remains consistent with processed banking transactions. This process provides an authoritative basis for customer account access and subsequent transaction decisions. |
|
CBS-1.6 |
Customer Account Enquiry and Information Access |
Enables customers and authorised MBSB personnel to obtain current account information through permitted channels. This includes access to balances, transaction histories, account status and other relevant deposit account information. The process supports customers' ability to understand the availability and movement of their funds and is therefore an important component of continued account access during both normal operations and disruptions. |
|
CBS-1.7 |
Account Statement and Transaction Information Provision |
Produces and makes available account statements and other formal transaction information relating to deposit accounts. Activities include compiling account activity, generating periodic or requested statements, presenting information through available channels and handling requests for historical account information. This process enables customers to review and reconcile account activity and identify discrepancies. |
|
CBS-1.8 |
Account Access Request and Instruction Processing |
Receives and processes authorised customer requests and instructions associated with accessing or managing deposit accounts. Activities include receiving instructions through available service channels, confirming that the request relates to an eligible account, performing required validations and routing the instruction for completion. It provides the operational bridge between customer access channels and underlying account processing. |
|
CBS-1.9 |
Account Access Validation and Control |
Ensures that requests to access deposit accounts are subject to appropriate customer, account and transaction controls before access or processing is permitted. Activities may include verifying account eligibility, checking applicable restrictions, validating authority and applying relevant operational controls. Detailed authentication technology is treated as a dependency and, where appropriate, linked to MBSB's separate CBS-8 Customer Transaction Authentication and Authorisation Services. |
|
CBS-1.10 |
Account Access Exception and Rejection Management |
Manages situations where customers cannot access an account or an account-related request cannot be processed as usual. Activities include identifying failed or rejected requests, determining the cause, managing operational exceptions, correcting eligible processing issues and directing cases requiring further investigation or customer intervention. The process prevents unresolved exceptions from unnecessarily prolonging customer loss of access. |
|
CBS-1.11 |
Account Restriction and Access Restoration |
Manages the controlled restoration of customer account access following legitimate restrictions, security interventions, administrative blocks or other access-related events. Activities include confirming the conditions for restoration, obtaining required approvals, removing eligible restrictions and validating that normal access has been re-established. This Sub-CBS is particularly important when customers retain funds with MBSB but temporarily lose access to them. |
|
CBS-1.12 |
Deposit Account Reconciliation and Integrity Management |
Ensures that deposit account balances, transaction records and related processing information remain complete and consistent. Activities include account and transaction reconciliation, identification of discrepancies, investigation of unmatched or incorrect entries, correction of authorised errors and confirmation of account record integrity. This process becomes especially important following technology outages, interrupted processing or recovery events. |
|
CBS-1.13 |
Account Access Service Monitoring and Exception Escalation |
Monitors the operational delivery of deposit and account access processes to identify deterioration, abnormal conditions, processing failures or emerging service disruptions. Activities include reviewing service exceptions, operational indicators, processing backlogs and customer access issues and escalating material problems to appropriate operational, technology, incident management or management teams. |
|
CBS-1.14 |
Customer Account Access Incident Management |
Coordinates the business response when an incident materially affects customers' ability to access deposit accounts or account information. Activities include assessing the service impact, determining affected processes and customer groups, coordinating with relevant operations and technology teams, prioritising critical service restoration and managing business decisions required during the disruption. This process interfaces with enterprise incident and crisis management arrangements without duplicating them. |
|
CBS-1.15 |
Disrupted Account Access Customer Assistance |
Provides account-related assistance to customers affected by disruption to normal access arrangements. Activities include identifying affected customer enquiries, providing approved information on account availability or alternative access arrangements, supporting customers experiencing access difficulties and escalating priority cases. Where broader disruption communications or customer support capabilities are required, this process interfaces with CBS-9 Customer Support and Assistance During Banking Disruptions. |
|
CBS-1.16 |
Alternative Account Access and Continuity Processing |
Enables essential account access activities to continue through approved alternative arrangements when normal processing or delivery channels are unavailable. Activities may include activating alternative operating procedures, prioritising essential customer requirements, applying authorised workarounds and coordinating available alternative channels or processing arrangements. The purpose is to maintain an acceptable level of CBS-1 while normal service is being restored. |
|
CBS-1.17 |
Deposit Account Processing Recovery and Reconciliation |
Restores interrupted deposit account processing following a significant operational or technology disruption. Activities include confirming recovery readiness, restarting or reconnecting affected processing, addressing queued or incomplete transactions, reconciling transactions processed before and during the disruption and verifying the integrity of recovered account records before normal processing resumes. |
|
CBS-1.18 |
Account Access Service Restoration and Validation |
Coordinates the controlled return of CBS-1 to normal service following disruption. Activities include validating restored account access, confirming processing capacity and the integrity of account information, checking outstanding exceptions and backlogs, monitoring service stability, and obtaining appropriate confirmation that normal operating arrangements can resume. Lessons and residual weaknesses identified during restoration should feed into subsequent resilience improvement activities. |
End-to-End Process Structure
The proposed Sub-CBS catalogue can be viewed across the lifecycle of CBS-1 as follows:
|
Service Lifecycle |
Principal Sub-CBS |
|
Establish |
CBS-1.1 Deposit Account Establishment and Activation |
|
Maintain |
CBS-1.2 Customer and Account Information Maintenance; CBS-1.3 Account Status and Access Administration |
|
Process |
CBS-1.4 Deposit Receipt and Account Credit Processing; CBS-1.5 Account Balance and Transaction Record Processing |
|
Provide Access |
CBS-1.6 Customer Account Enquiry and Information Access; CBS-1.7 Account Statement and Transaction Information Provision; CBS-1.8 Account Access Request and Instruction Processing |
|
Validate and Control |
CBS-1.9 Account Access Validation and Control |
|
Manage Exceptions |
CBS-1.10 Account Access Exception and Rejection Management; CBS-1.11 Account Restriction and Access Restoration; CBS-1.12 Deposit Account Reconciliation and Integrity Management |
|
Monitor and Respond |
CBS-1.13 Account Access Service Monitoring and Exception Escalation; CBS-1.14 Customer Account Access Incident Management; CBS-1.15 Disrupted Account Access Customer Assistance |
|
Maintain During Disruption |
CBS-1.16 Alternative Account Access and Continuity Processing |
|
Recover and Restore |
CBS-1.17 Deposit Account Processing Recovery and Reconciliation; CBS-1.18 Account Access Service Restoration and Validation |
This structure provides a service-oriented view rather than organising the CBS according to MBSB's organisational departments.
That distinction is important. A single Sub-CBS may involve multiple business units, while one business unit may contribute to several Sub-CBS processes. The subsequent dependency-mapping exercise should reveal these relationships.
Important Boundaries with Other MBSB Critical Business Services
CBS-1 should not be analysed in isolation. Several of MBSB's other proposed Critical Business Services are likely to have important relationships with Customer Deposit and Account Access Services.
For example:
-
CBS-3 Digital Banking Services may serve as an important delivery channel for customers to access CBS-1.
-
CBS-4 Cash Access and Cash Transaction Services may enable customers to physically access funds held in deposit accounts.
-
CBS-8 Customer Transaction Authentication and Authorisation Services may provide the authentication and authorisation capability required before account access or certain account instructions can proceed.
-
CBS-9 Customer Support and Assistance During Banking Disruptions may support customers when CBS-1 is materially disrupted.
These relationships should not result in duplicate processes across multiple CBS catalogues.
Instead, they should be captured as interconnections and dependencies during the next stage of the Operational Resilience implementation.
This distinction will allow MBSB to identify where the failure of one CBS, process or shared resource could affect another critical service.
Preparing CBS-1 for Dependency Mapping
The Sub-CBS catalogue provides the process layer upon which MBSB can build its detailed dependency map.
BNM's Discussion Paper notes that disruptions may propagate across a network of people, processes, data, technology, facilities and business units, and that mapping such interdependencies can help identify vulnerabilities, critical points of failure, concentrations and interlinkages.
Accordingly, each CBS-1.x process should subsequently be mapped against relevant categories such as:
|
Dependency Category |
Examples for Subsequent Analysis |
|
People |
Process owners, operational teams, specialist personnel, technology support, customer service personnel |
|
Process |
Upstream processes, downstream processes, shared processes and other CBSs |
|
Technology |
Core banking capabilities, customer access platforms, databases, middleware, interfaces, monitoring and recovery capabilities |
|
Information/Data |
Customer records, account balances, transaction records, mandates, access information and reconciliation data |
|
Facilities |
Operational locations, branches, processing locations, data centres and recovery facilities where relevant |
|
Third Parties |
Technology providers, telecommunications providers, infrastructure providers and outsourced service arrangements |
|
External Infrastructure |
Industry networks and other shared infrastructure required to maintain the relevant service |
The actual dependencies should be confirmed by MBSB's business, operations and technology owners rather than assumed solely from the high-level CBS definition.
Relationship to Impact Tolerance
The decomposition of CBS-1 also provides the basis for determining where disruption begins to threaten the customer outcome.
BNM distinguishes an outward-looking tolerance for disruption from traditional internal recovery metrics such as Maximum Tolerable Downtime and Recovery Time Objective.
The Discussion Paper notes that impact tolerances should consider customer and stakeholder outcomes and establish a boundary between acceptable and unacceptable disruption.
For CBS-1, this means MBSB should ultimately consider more than the recovery time of an individual application.
Relevant questions may include:
- How long can customers reasonably be prevented from accessing their deposit accounts?
- How many customers could be affected before the impact becomes intolerable?
- Which customer groups may experience greater harm from prolonged loss of access?
- What minimum level of account access must MBSB maintain during a severe disruption?
- How long can account balances or transaction information remain unavailable or unreliable?
- At what point could transaction backlogs create unacceptable customer consequences?
- What alternative means of accessing the account are realistically available?
- Could simultaneous disruption of digital, branch or cash-access channels cause the tolerance to be breached?
The Sub-CBS structure makes these questions easier to analyse because MBSB can determine which processes must be restored or maintained to protect the overall CBS outcome.
Foundation for Severe but Plausible Scenario Testing
Once the dependencies and impact tolerances for CBS-1 have been established, the Sub-CBS catalogue can be used to develop severe but plausible scenarios.
BNM's emerging direction emphasises that isolated failure testing may be insufficient and that financial institutions should consider scenarios severe enough to reveal deficiencies while remaining reasonably plausible, including multi-layered failures.
For CBS-1, future scenario testing could therefore challenge different parts of the end-to-end process chain rather than simply assume the failure of one application.
Potential scenario themes could include:
- prolonged unavailability of core deposit account processing;
- simultaneous loss of digital account access and alternative customer channels;
- corruption or inconsistency of account balance and transaction data;
- cyber compromise requiring precautionary restrictions on account access;
- failure of a critical technology or telecommunications provider;
- disruption occurring during unusually high customer demand;
- recovery platform failure during restoration;
- large transaction backlogs following prolonged processing interruption; or
- concurrent technology, third-party and workforce disruption.
These are scenario themes rather than predetermined tests. The final scenarios should be designed after MBSB has completed its dependency mapping and identified the vulnerabilities and concentration points associated with CBS-1.
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The decomposition of CBS-1 Customer Deposit and Account Access Services into operationally meaningful Sub-CBS processes provides MBSB with a structured view of how this critical customer outcome is delivered.
The proposed catalogue of 18 Sub-CBS processes covers the lifecycle from account establishment and maintenance through account access, processing, validation and exception management to disruption response, continuity processing, recovery and final service restoration.
This process-level understanding is essential because operational resilience cannot be assessed effectively by examining individual systems or organisational functions independently.
BNM's 2025 Operational Resilience Discussion Paper reinforces the need for financial institutions to understand critical services, map internal and external interdependencies, establish tolerances for disruption and assess resilience under severe but plausible scenarios.
For MBSB, the Sub-CBS catalogue should therefore become the starting point for the next implementation stage:
CBS-1 Customer Deposit and Account Access Services
During dependency mapping, each Sub-CBS should be connected to the people, technology, information, facilities, third parties and other processes required for its delivery.
This will allow MBSB to identify common dependencies, concentration risks, potential single points of failure, and vulnerabilities that could affect the overall Critical Business Service.
The resulting end-to-end view can then inform impact tolerance analysis and provide the basis for selecting realistic severe but plausible scenarios.
Scenario testing can subsequently determine whether MBSB's existing arrangements can maintain or restore Customer Deposit and Account Access Services within the established tolerance for disruption.
In this way, the Sub-CBS catalogue is not simply a process inventory. It becomes the operational foundation for understanding, testing and progressively strengthening the resilience of one of MBSB's most important customer-facing banking services.
Regulatory reference: Bank Negara Malaysia, Operational Resilience – Discussion Paper, issued 19 December 2025. BNM Operational Resilience Discussion Paper
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