---
title: [OR] [MBSB] [E3] [CBS] [2] [ITo] Establish Impact Tolerances
description: [OR] [MBSB] [E3] [CBS] [2] [ITo] Establish Impact Tolerances
image: https://blog.bcm-institute.org/hubfs/MBSB%20Graphic%20Folder/MBSB%20CBS%202/%5BOR%5D%20%5BMBSB%5D%20%5BE3%5D%20%5BCBS%5D%20%5B2%5D%20%5BITo%5D%20Domestic%20Funds%20Transfer%20and%20Payment%20Services.jpg
---
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###### Operational Resilience in Action: The MBSB Approach
![BB OR \[A\] 18](https://blog.bcm-institute.org/hs-fs/hubfs/OR%20picture/OR%20Pictures%20A/BB%20OR%20Folder%20A/BB%20OR%20%5BA%5D%2018.jpg?width=2000&height=1333&name=BB%20OR%20%5BA%5D%2018.jpg "BB OR [A] 18")
# \[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[ITo\] Establish Impact Tolerances
[![\[OR\] \[MBSB\] \[Full Banner\] Operational Resilience in Action The MBSB Bank's Approach ](https://no-cache.hubspot.com/cta/default/3893111/567eecca-dbad-4a1a-8465-5d45335ce5da.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/567eecca-dbad-4a1a-8465-5d45335ce5da)
Setting an Impact Tolerance for CBS-2: Domestic Funds Transfer and Payment Services enables MBSB to set the maximum disruption it can tolerate before customers, counterparties, financial markets, or the bank itself experience unacceptable harm.
The assessment must consider the complete domestic payment lifecycle rather than the recovery capability of an individual application or department.
Accordingly, the 24 identified Sub-Critical Business Services (Sub-CBS) provide the operational basis for evaluating how failures in payment initiation, authentication, validation, processing, settlement, reconciliation, monitoring and recovery may affect the end-to-end service.
The assessment integrates Cybersecurity and Information and Communications Technology (ICT) risks throughout because cyberattacks, data corruption, technology concentration, infrastructure outages, network failures, and compromised access controls can disrupt multiple Sub-CBS processes simultaneously and cause the overall Critical Business Service to exceed its Impact Tolerance.
[](https://cta-redirect.hubspot.com/cta/redirect/3893111/0430108a-ef49-43aa-ac7d-ee6bb474eba8)
[Dr Goh Moh Heng](https://blog.bcm-institute.org/ebook-or/author/dr-goh-moh-heng) Oct 14, 2026
###### Operational Resilience Certified Planner-Specialist-Expert
### [![x \[OR\] \[MBSB\] Legal Disclaimer Banner](https://no-cache.hubspot.com/cta/default/3893111/d779f9ab-aec0-4cdd-a906-81e7841c3e1c.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/d779f9ab-aec0-4cdd-a906-81e7841c3e1c)
### [](https://cta-redirect.hubspot.com/cta/redirect/3893111/0430108a-ef49-43aa-ac7d-ee6bb474eba8)**CBS-2 Domestic Funds Transfer and Payment Services**
#### Introduction
[![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[ITo\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/e124bae1-4ad4-4c27-8400-1fe1d67fbea9.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/e124bae1-4ad4-4c27-8400-1fe1d67fbea9)
[](https://cta-redirect.hubspot.com/cta/redirect/3893111/1e4399ef-c884-48b2-a56d-c68bd01abfcf)
Setting an Impact Tolerance for CBS-2: Domestic Funds Transfer and Payment Services enables MBSB to establish the maximum disruption it is prepared to tolerate before customers, counterparties, financial markets or the bank itself experience unacceptable harm.
The assessment must consider the complete domestic payment lifecycle rather than the recovery capability of an individual application or department. Accordingly, the 24 identified Sub-Critical Business Services (Sub-CBS) provide the operational basis for evaluating how failures in payment initiation, authentication, validation, processing, settlement, reconciliation, monitoring and recovery may affect the end-to-end service.
The assessment integrates Cybersecurity and Information and Communications Technology (ICT) risks throughout because cyberattacks, data corruption, technology concentration, infrastructure outages, network failures, and compromised access controls can disrupt multiple Sub-CBS processes simultaneously and cause the overall Critical Business Service to exceed its Impact Tolerance.
#### **Purpose and Assessment Principles**
Impact Tolerance establishes a boundary between disruption that MBSB can manage without unacceptable harm and disruption that becomes intolerable.
For domestic payment services, harm is not determined solely by the length of an outage. A short disruption during a high-volume payroll or payment period may have more serious consequences than a longer disruption affecting a low-volume channel during an off-peak period.
Similarly, a payment processing system may be technically available while customers can't authenticate, funds are posted incorrectly, or external payment infrastructure prevents transactions from completing.
MBSB should therefore assess Impact Tolerance using several dimensions simultaneously:
- **Duration:** How long essential domestic payment services are unavailable or materially degraded.
- **Customer impact:** How many customers are affected and whether vulnerable customers or essential payments are disproportionately impacted.
- **Transaction impact:** The number, value and urgency of delayed, rejected or incomplete transactions.
- Service capability: Whether MBSB can continue processing payments at a safe and meaningful level.
- **Financial integrity:** Whether account balances, payment instructions, transaction states and settlement records remain accurate.
- **Interbank impact:** Whether disruption affects counterparties, payment infrastructure or other financial institutions.
- **Regulatory impact:** Whether applicable statutory, supervisory, payment-system or reporting obligations are affected.
- **Cyber and ICT exposure:** Whether common technology failures, security compromises or external dependencies could cause simultaneous service disruption.
The assessment should use the previously developed Mapping of Interconnections and Interdependencies for CBS-2 to identify which process failures are likely to propagate across the service.
##### **Impact Tolerance and other Recovery Measures**
| Measure | Meaning | Relationship to CBS-2 Impact Tolerance |
| --- | --- | --- |
| Impact Tolerance | Maximum disruption before unacceptable harm occurs. | Defines the service-level boundary that MBSB must seek to remain within. |
| Recovery Time Objective (RTO) | Target time for recovering a process, system or capability. | Set individual RTOs to support overall service tolerance, with allowance for validation and transaction backlog clearance. |
| Recovery Point Objective (RPO) | Target maximum data loss measured in time. | Supports payment data recoverability but does not establish whether financial records are accurate or whether payments were executed more than once. |
| Maximum Tolerable Period of Disruption (MTPD) | Maximum period a business activity can be disrupted before unacceptable consequences arise under BCM analysis. | May inform the assessment, but CBS-2 Impact Tolerance considers broader customer, financial-system and service outcomes. |
| Service Level Agreement (SLA) | Contractual or operational service performance commitment. | Provides supporting performance expectations but cannot independently define unacceptable customer or systemic harm. |
| System availability target | Expected percentage of time an application or platform is available. | Provides technical performance evidence; system availability does not necessarily mean customers can complete payments. |
For example, recovering the Payment Processing Platform within two hours does not demonstrate compliance with a three-hour service-level Impact Tolerance if an additional two hours are required to restore connectivity, validate transactions and clear essential payment backlogs.
#### **Methodology for Assessing Levels of Harm**
The proposed assessment uses a five-level harm classification.
| Level of Harm | Assessment Criteria | Illustrative CBS-2 Consequences |
| --- | --- | --- |
| Very Low | Negligible interruption with no material customer impact. | Brief isolated processing delay, automatically resolved without financial consequence. |
| Low | Limited disruption affecting a small number of transactions or customers. | Minor delays with effective alternatives and no significant financial harm. |
| Medium | Noticeable disruption affecting a defined customer group or payment channel. | Payment delays, increasing enquiries and manageable backlogs requiring operational intervention. |
| High | Major disruption affecting significant customer groups, essential payments or several channels. | Customers unable to meet important financial obligations; substantial payment backlogs or prolonged uncertainty. |
| Very High | Severe or potentially intolerable harm involving widespread customer impact, financial integrity failure or material interbank consequences. | Widespread inability to transfer funds, significant incorrect postings, systemic payment disruption or serious regulatory consequences. |
The ratings in the following table represent the credible potential severity of a material or prolonged disruption, taking account of the role of each Sub-CBS in the end-to-end service. They are not assessments of failure likelihood, confirmed MBSB residual risk or automatically applicable regulatory classifications.
A Medium-rated process can still contribute to a Very High overall service impact if it fails simultaneously with other processes or if the disruption is prolonged.
[![Banner \[Table\] \[OR\] \[E3\] Establish Impact Tolerance](https://no-cache.hubspot.com/cta/default/3893111/627c33a8-714d-40af-9a2b-0d7957fb8afa.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/627c33a8-714d-40af-9a2b-0d7957fb8afa)
#### **Sub-CBS Impact Tolerance and Potential Harm Assessment**
This table evaluates how disruption to each of the 24 Sub-CBS processes could affect CBS-2, the harm that may result and the indicators MBSB should monitor.
Table P4: Establish Impact Tolerance for CBS-2
| Sub-CBS Code | Name of Sub-CBS | Potential Disruption | Potential Harm | Level of Harm | Key Harm Indicators |
| --- | --- | --- | --- | --- | --- |
| CBS-2.1 | Customer Payment Instruction Initiation | Digital or branch payment initiation becomes unavailable due to channel, network, or application failure. | Customers cannot initiate domestic transfers or settle obligations; disruption across several channels can rapidly increase harm. | High — direct customer-facing unavailability | Outage duration; affected channels; customers unable to initiate; failed initiation attempts; essential payments delayed. |
| CBS-2.2 | Payment Instruction Capture and Registration | Instructions are not recorded, are duplicated or remain untraceable after submission. | Payments may be lost, repeated or delayed; uncertainty over accepted instructions may lead to customer financial loss. | High — transaction integrity and traceability risk | Unregistered instructions; duplicate references; transaction discrepancies; unresolved instructions; processing delay. |
| CBS-2.3 | Payment Instruction Completeness Validation | Validation rules fail, reject valid instructions or allow incomplete payments to proceed. | Increased payment rejection, misprocessing, rework and customer delays. | Medium — generally manageable unless widespread | Validation rejection rate; invalid instructions accepted; affected transactions; exception backlog; resolution time. |
| CBS-2.4 | Customer Authentication and Payment Authorisation | Customers cannot authenticate or authorise payments, or authorisation controls become unreliable. | Widespread inability to complete transfers or risk of unauthorised payments and customer financial loss. | Very High — security and availability consequences | Authentication failure rate; customers blocked; unauthorised payment events; outage duration; affected payment value. |
| CBS-2.5 | Account Eligibility and Payment Limit Validation | Account status or payment limits cannot be verified or are applied incorrectly. | Eligible payments are blocked or restricted transactions may be processed incorrectly. | High — account control and payment availability risk | Failed eligibility checks; erroneous limit decisions; blocked customers; incorrect approvals; delayed payment value. |
| CBS-2.6 | Payment Fraud and Compliance Screening | Fraud screening becomes unavailable, compromised or unable to process transactions at required capacity. | Payments may be suspended to preserve controls, or unsafe transactions may create financial and regulatory harm. | Very High — potential fraud and compliance consequences | Unscreened or held transactions; fraud losses; screening backlog; alert latency; control bypass incidents. |
| CBS-2.7 | Beneficiary and Payment Destination Validation | Beneficiary details cannot be validated or destination information is incorrect. | Payments may be delayed, rejected or misdirected, potentially causing financial loss. | High — payment accuracy and customer harm | Invalid beneficiary rate; misdirected payments; rejected transfers; unresolved beneficiary verification failures. |
| CBS-2.8 | Funds Availability and Account Balance Verification | Available balances cannot be accessed or are inaccurate. | Payments cannot be safely processed, or incorrect funds decisions may affect account integrity. | Very High — shared core banking and financial integrity dependency | Balance-service outage; failed funds checks; incorrect balance decisions; blocked payments; reconciliation differences. |
| CBS-2.9 | Payment Transaction Classification and Processing | Payment processing rules fail or transactions are classified or routed incorrectly. | Domestic payments may be rejected, delayed, misprocessed or sent through unsuitable processing arrangements. | High — broad payment processing disruption | Processing failure rate; misclassified transactions; queue backlog; delayed payment value; processing capacity. |
| CBS-2.10 | Customer Account Debit and Transaction Posting | Core ledger posting fails, duplicates transactions or produces inconsistent account balances. | Incorrect debits, missing postings or unreliable financial records may cause significant customer harm. | Very High — financial integrity failure | Duplicate debits; unposted transactions; ledger differences; affected accounts; unresolved transaction value. |
| CBS-2.11 | Payment Instruction Routing and Transmission | Payment gateway, network interface or transmission service fails. | Payments cannot reach the required internal or external execution arrangement. | High — critical processing hand-off failure | Transmission failure rate; queue depth; delayed instructions; gateway outage duration; affected payment schemes. |
| CBS-2.12 | Internal Funds Transfer Execution | Internal transfer engine cannot complete debit-and-credit processing. | Transfers between MBSB accounts are delayed or incomplete, potentially leaving balances inconsistent. | High — direct customer payment and account impact | Failed internal transfers; incomplete debit-credit pairs; affected accounts; unresolved transaction value. |
| CBS-2.13 | Domestic Interbank Payment Execution | External payment connectivity or interbank execution fails. | Customers cannot complete transfers to other banks; financial obligations and time-sensitive payments are delayed. | Very High — significant customer and interbank consequences | Failed interbank transfers; affected banks; delayed transaction value; service outage duration; backlog. |
| CBS-2.14 | Interbank Clearing and Settlement Coordination | Settlement information, funding arrangements, or clearing coordination becomes unavailable. | Payment completion may be delayed or uncertain, potentially affecting counterparties and financial obligations. | Very High — settlement and financial-system exposure | Unsettled obligations; settlement delays; liquidity shortfalls; unmatched settlement records; affected participants. |
| CBS-2.15 | Beneficiary Credit and Payment Completion Management | Beneficiary credits fail, or payment completion status cannot be established. | Beneficiaries may not receive funds; customers may face financial loss or repeated payment attempts. | Very High — direct failure of the intended payment outcome | Uncredited payments; pending completion; delayed beneficiary credits; affected customers; duplicate payment attempts. |
| CBS-2.16 | Payment Status Confirmation and Customer Notification | Payment notifications fail, or the system communicates an incorrect transaction status. | Customers may repeat payments, miss obligations, or be uncertain about payment outcomes. | Medium — can escalate when combined with processing failures | Missing notifications; incorrect status messages; repeated payments; complaints; notification latency. |
| CBS-2.17 | Payment Reconciliation and Financial Control | Payment and settlement records cannot be reconciled, or discrepancies remain unresolved. | Financial errors may remain undetected; transaction integrity and safe restoration may be compromised. | Very High — financial integrity and control failure | Unmatched transactions; reconciliation backlog; unreconciled value; ageing exceptions; duplicate or missing postings. |
| CBS-2.18 | Payment Records and Transaction Audit Management | Transaction records, audit trails or payment histories become unavailable or corrupted. | Payment investigations, reconciliation, customer dispute resolution and recovery validation may be impaired. | High — evidence and recoverability risk | Missing records; inaccessible transaction histories; audit gaps; records recovery time; unresolved investigations. |
| CBS-2.19 | Payment Service Monitoring and Operational Control | Monitoring fails to detect payment outages, queue growth or processing deterioration. | Delayed detection lets disruption escalate and reduces the time available to intervene before tolerance is breached. | High — impaired detection and response | Detection delay; unmonitored transactions; alert failures; backlog growth; time from incident onset to escalation. |
| CBS-2.20 | Payment Exception, Rejection and Return Management | Failed or rejected transactions cannot be investigated or corrected. | Customers experience prolonged unresolved payments, incorrect balances or delayed returns. | High — accumulating customer harm | Unresolved exceptions; delayed returned payments; correction backlog; customer complaints; ageing rejected transactions. |
| CBS-2.21 | Payment Dispute and Transaction Investigation | Payment disputes and transaction investigations cannot be resolved within acceptable periods. | Customer financial losses and uncertainty may persist, potentially increasing complaints and regulatory exposure. | Medium — potentially High for large-scale fraud or integrity events | Open disputes; investigation age; disputed value; customer complaints; unresolved duplicate transfers. |
| CBS-2.22 | Payment Disruption Assessment and Service Escalation | Material service disruption is not recognised or escalated promptly. | Delayed decisions and ineffective incident coordination may allow customer harm to become severe. | High — response delay can accelerate breach | Time to detect; time to escalate; affected customers; time to activate response; tolerance consumption. |
| CBS-2.23 | Payment Continuity and Alternative Processing | Approved alternative processing cannot be activated or lacks sufficient capacity. | Essential payments remain unavailable during disruption, potentially causing widespread customer harm. | Very High — failure of essential continuity capability | Alternative processing capacity; essential payments completed; backlog; activation time; affected customers. |
| CBS-2.24 | Payment Service Recovery and Controlled Restoration | Payment services cannot be safely restored, or recovery introduces duplicate, missing or incorrect transactions. | Extended disruption or financial integrity failures may cause unacceptable harm to customers and interbank systems. | Very High — prolonged outage and unsafe restoration | Recovery duration; transaction validation failures; duplicate payments; unresolved backlog; reconciliation differences. |
##### **Interpretation of Table P4: Establish Impact Tolerance for CBS-2**
The assessment identifies nine Sub-CBS processes with a Very High potential harm rating: CBS-2.4, CBS-2.6, CBS-2.8, CBS-2.10, CBS-2.13, CBS-2.14, CBS-2.15, CBS-2.17, CBS-2.23 and CBS-2.24.
These ten processes reflect the combination of security, funds availability, financial integrity, interbank execution, settlement, payment completion, continuity, and restoration risks.
Their importance does not mean that every failure immediately breaches CBS-2's Impact Tolerance. Instead, these processes warrant heightened attention because material failures can rapidly affect customer payment outcomes, cause financial loss or compromise safe service recovery.
MBSB should also consider cumulative harm.
A payment notification failure may initially be rated Medium, but when combined with incomplete payment processing and unavailable customer support, it could substantially increase the severity of a broader CBS-2 disruption.
#### **Cyber and ICT Risk Integration with Impact Tolerance**
Evaluate cyber and ICT risks by their consequences for CBS-2, not merely the technical severity of a security incident or infrastructure failure.
For example, a Distributed Denial-of-Service (DDoS) attack may initially affect a digital channel, but if it also prevents customers from accessing alternative payment arrangements, the resulting customer harm can become substantially greater.
Similarly, ransomware affecting the core banking ledger may create both service unavailability and uncertainty over the accuracy of previously processed transactions.
BNM's December 2025 Discussion Paper emphasises the growing importance of cyber resilience, technology dependencies, external service providers, data integrity and the ability to withstand concurrent failures.
It also explains how the existing BCM and Risk Management in Technology frameworks contribute to operational resilience.
Table 2 integrates these exposures into the assessment of every Sub-CBS.
| Sub-CBS Code | Name of Sub-CBS | Cyber and ICT Risk Linkage | Contribution to Impact Tolerance Breach | Proactive Risk Management Action | Evidence of Proactive Risk Management |
| --- | --- | --- | --- | --- | --- |
| CBS-2.1 | Customer Payment Instruction Initiation | DDoS attacks, digital channel outages, API failures, telecommunications disruption and failed application changes. | Customers cannot initiate payments; simultaneous channel failures may rapidly exceed acceptable customer-impact thresholds. | Implement DDoS protection, channel redundancy, capacity monitoring, controlled deployment and tested alternative payment channels. | DDoS test reports; channel availability monitoring; failover results; change testing records; alternative-channel exercise reports. |
| CBS-2.2 | Payment Instruction Capture and Registration | Database failure, message queue corruption, API interruption, ransomware and transaction duplication. | Lost or duplicated instructions create financial integrity concerns and may prevent safe processing. | Implement durable message handling, unique transaction identifiers, database replication, integrity checks and controlled transaction replay. | Database recovery reports; message queue resilience tests; duplicate-detection test results; transaction integrity assurance reports. |
| CBS-2.3 | Payment Instruction Completeness Validation | Defective validation rules, corrupted reference data, application defects and failed technology changes. | Incorrect validation may cause mass rejection or unsafe processing, increasing delays and exceptions. | Apply controlled rule changes, automated regression testing, reference-data validation and exception monitoring. | Change approvals; regression test results; validation exception reports; application quality assurance records. |
| CBS-2.4 | Customer Authentication and Payment Authorisation | Identity platform outage, credential compromise, phishing, privileged access abuse, authentication API failure and DDoS attacks. | Customers cannot authorise payments, or unauthorised transactions create unacceptable financial harm. | Strengthen multifactor authentication, privileged access controls, transaction authorisation, identity platform resilience and fraud monitoring. | Penetration testing; access certification; privileged access reviews; authentication failover tests; fraud-control test results. |
| CBS-2.5 | Account Eligibility and Payment Limit Validation | Core banking outage, corrupted account restrictions, database inconsistency and unauthorised limit changes. | Legitimate payments may be blocked, or restricted payments may be incorrectly approved; widespread failure affects CBS-2 availability. | Implement account-data integrity controls, dual control for material limit changes, core banking resilience and exception monitoring. | Account control testing; limit-change audit trails; core banking recovery tests; reconciliation reports; control exception records. |
| CBS-2.6 | Payment Fraud and Compliance Screening | Screening engine failure, cyber compromise, outdated screening data, rules manipulation and third-party service interruption. | Payments may be suspended to preserve mandatory controls, or unsafe transactions may create serious financial and regulatory harm. | Maintain resilient screening services, rule-integrity controls, alert monitoring, tested contingency arrangements, and controlled escalation procedures. | Screening assurance reports; rule-change logs; fraud monitoring records; third-party assurance; incident exercises; compliance reviews. |
| CBS-2.7 | Beneficiary and Payment Destination Validation | Beneficiary database corruption, API manipulation, payment redirection attacks and external verification service outage. | Misdirected or rejected payments may cause financial loss and increase customer harm. | Validate destination data, secure payment APIs, monitor beneficiary changes and test fallback arrangements consistent with scheme requirements. | API security tests; beneficiary change monitoring; data integrity reports; external interface tests; fraud investigation findings. |
| CBS-2.8 | Funds Availability and Account Balance Verification | Core banking failure, balance-service outage, database corruption, ransomware and replication inconsistency. | Payments cannot be safely processed, or balances become unreliable; a shared failure can affect several CBSs. | Strengthen core banking high availability, ledger integrity monitoring, replication validation and cyber recovery arrangements. | Core banking failover reports; balance reconciliation; cyber recovery tests; database integrity reports; independent assurance findings. |
| CBS-2.9 | Payment Transaction Classification and Processing | Payment engine outage, application defects, rule corruption, capacity exhaustion and failed system changes. | Payments may be misclassified, delayed or incorrectly processed across multiple payment routes. | Apply transaction rule governance, performance monitoring, resilient processing architecture and controlled change deployment. | Processing capacity tests; regression tests; configuration reviews; application resilience reports; change management evidence. |
| CBS-2.10 | Customer Account Debit and Transaction Posting | Ransomware, ledger corruption, database failure, privileged access compromise and transaction replay errors. | Duplicate, missing or incorrect debits may create immediate unacceptable financial harm, regardless of outage duration. | Implement ledger integrity controls, privileged access restrictions, immutable or protected transaction records, recovery validation and duplicate prevention. | Ledger reconciliation; privileged access audit; database recovery tests; transaction replay testing; financial control attestations. |
| CBS-2.11 | Payment Instruction Routing and Transmission | Network outages, API gateway failures, certificate expiry, message corruption, DDoS, and telecommunications provider disruption. | Payments cannot reach execution systems or external networks, causing backlogs to accumulate and interbank delays. | Establish resilient gateways, network diversity, certificate lifecycle controls, queue monitoring and tested communication failover. | Network failover reports; certificate inventories; gateway monitoring; message integrity testing; provider assurance reports. |
| CBS-2.12 | Internal Funds Transfer Execution | Internal transfer engine failure, ledger inconsistency, application defect and transaction-state corruption. | Internal transfers may fail or produce unmatched debits and credits, affecting customers and account integrity. | Implement atomic transaction controls, duplicate prevention, resilient core banking processing and reconciliation-based restoration. | Internal transfer test results; debit-credit reconciliation; recovery exercise reports; transaction integrity testing. |
| CBS-2.13 | Domestic Interbank Payment Execution | External payment network outages, payment gateway failures, telecommunications disruptions, cyberattacks, and third-party ICT failures. | Interbank transfers cannot complete; widespread customer and counterparty harm may exceed service tolerance. | Test payment network contingency arrangements, gateway resilience, external incident coordination and payment queue recovery. | Payment network test records; provider assurance; gateway failover results; interbank scenario exercise reports; remediation tracking. |
| CBS-2.14 | Interbank Clearing and Settlement Coordination | Settlement interface failure, inaccurate settlement data, time synchronisation failure, network outage and liquidity system disruption. | Settlement uncertainty or delayed obligations may create significant financial and counterparty consequences. | Validate settlement data, monitor funding obligations, synchronise transaction timestamps, and test settlement-disruption procedures. | Settlement reconciliation; time synchronisation monitoring; liquidity contingency tests; payment infrastructure exercise records. |
| CBS-2.15 | Beneficiary Credit and Payment Completion Management | Credit posting failure, transaction-state corruption, incomplete acknowledgements and receiving-bank interface outages. | Beneficiaries do not receive funds, or payment completion cannot be verified; duplicate attempts may compound harm. | Implement verified transaction-state management, duplicate controls, beneficiary credit reconciliation and exception escalation. | Payment completion testing; transaction-state reconciliation; duplicate prevention reports; receiving-bank interface test results. |
| CBS-2.16 | Payment Status Confirmation and Customer Notification | Messaging service outage, inaccurate status APIs, telecommunications failure and unauthorised notification changes. | Customers cannot determine payment outcomes and may initiate duplicate payments or miss financial obligations. | Use verified transaction status, resilient notification channels, message-integrity controls, and customer-communication contingency plans. | Notification delivery reports; status accuracy testing; messaging provider assurance; customer communication exercise records. |
| CBS-2.17 | Payment Reconciliation and Financial Control | Corrupted settlement files, database failure, inaccurate financial data, ransomware and failed data integration. | Unreconciled transactions may conceal missing or duplicated payments and prevent safe restoration. | Implement automated reconciliation, independent record comparison, protected financial data and exception escalation thresholds. | Daily reconciliation reports; data integrity tests; unresolved exception registers; recovery validation; internal audit findings. |
| CBS-2.18 | Payment Records and Transaction Audit Management | Ransomware, unauthorised data alteration, storage failure, log deletion and backup compromise. | Loss of payment evidence prevents investigation, reconciliation and reliable recovery decisions. | Protect audit trails, restrict privileged access, maintain recoverable records and periodically test restoration of transaction evidence. | Audit-log integrity reports; backup restoration tests; access reviews; records retention assurance; cyber recovery reports. |
| CBS-2.19 | Payment Service Monitoring and Operational Control | Monitoring platform outage, alert suppression, telemetry loss, time synchronisation failure and security monitoring compromise. | Payment failures remain undetected, allowing disruption and backlog growth to consume the available tolerance. | Implement independent service monitoring, synthetic transaction checks, alert escalation, monitoring redundancy and time synchronisation controls. | Monitoring coverage reports; synthetic transaction results; alert response records; monitoring failover tests; detection exercises. |
| CBS-2.20 | Payment Exception, Rejection and Return Management | Case management outage, payment record corruption, interface failures and automation defects. | Failed or returned payments remain unresolved, creating financial uncertainty and increasing customer harm. | Maintain resilient exception workflows, prioritised case queues, controlled adjustment procedures and tested manual escalation. | Exception ageing reports; workflow recovery tests; adjustment approvals; backlog monitoring; operational control testing. |
| CBS-2.21 | Payment Dispute and Transaction Investigation | Investigation platform outage, loss of audit evidence, cyber fraud incidents and unauthorised case changes. | Disputes cannot be resolved promptly, prolonging financial loss and customer uncertainty. | Protect investigation evidence, secure case management, maintain specialist response capacity and test dispute continuity procedures. | Conduct investigation case audits; test evidence integrity; review access; run dispute recovery exercises; monitor complaint reports. |
| CBS-2.22 | Payment Disruption Assessment and Service Escalation | Monitor failures, concealed cyber incidents, communications outages, inaccurate impact dashboards, and incident platform failures. | Delayed detection or escalation reduces the time available to prevent CBS-2 from breaching its tolerance. | Integrate cyber, ICT and business incident escalation; establish service-level impact dashboards and predefined activation triggers. | Incident response exercises; escalation time records; crisis simulations; impact dashboard testing; management committee minutes. |
| CBS-2.23 | Payment Continuity and Alternative Processing | Recovery infrastructure outage, shared technology concentration, compromised backup environments and alternative-channel failure. | Essential payment capability cannot be maintained, making a tolerance breach likely during prolonged disruption. | Test independent alternative arrangements, minimum payment capacity, specialist staffing, cyber-safe recovery and third-party contingency capabilities. | Business continuity exercise results; alternative processing tests; recovery-site assurance; staffing exercises; third-party contingency reports. |
| CBS-2.24 | Payment Service Recovery and Controlled Restoration | Ransomware persistence, corrupted backups, failed disaster recovery, incorrect transaction replay and premature system restoration. | Extended service unavailability or incorrect restoration may produce duplicate, missing or misposted payments, potentially breaching tolerance immediately. | Implement clean recovery environments, transaction-state validation, controlled backlog release, reconciliation gates and formal service restoration approval. | Disaster recovery reports; cyber recovery exercises; backup integrity testing; reconciliation sign-offs; restoration approvals; lessons-learned reports. |
##### **Key Cyber and ICT Risk Observations**
The assessment identifies several technology-related dependencies that can create widespread consequences for CBS-2.
Core banking concentration is particularly important because account validation, funds verification, debit posting, internal transfer execution and reconciliation may depend on common ledger services.
A core banking failure can therefore affect multiple Sub-CBS processes simultaneously.
Authentication and security-control availability are equally significant.
If MBSB cannot reliably authenticate customers or screen transactions, the bank may need to restrict payment processing to prevent fraud or regulatory breaches.
Restoring availability by bypassing essential controls would not represent a successful resilience outcome.
External payment infrastructure introduces dependencies outside MBSB's direct operational control.
Payment network or telecommunications failures may prevent interbank transactions from completing even when internal banking platforms remain available.
Data integrity and transaction-state management require special attention. Incorrect account debits, duplicate transfers, missing beneficiary credits and unreconciled settlement records may cause unacceptable harm without a prolonged outage.
Cyber recovery capability must therefore extend beyond restarting applications. It should demonstrate that MBSB can recover trusted data, determine the status of interrupted payments and restore transaction processing without creating additional financial harm.
#### **Recommended Impact Tolerance for CBS-2: Domestic Funds Transfer and Payment Services**
##### **Proposed Impact Tolerance statement**
For this implementation case study, the following statement is recommended for MBSB's consideration:
MBSB should ensure that CBS-2 Domestic Funds Transfer and Payment Services can continue delivering essential domestic payment outcomes during severe but plausible disruption without causing unacceptable customer, counterparty, financial-system, or regulatory harm.
As an initial calibration assumption, material disruption to essential payment capability should not exceed two hours. During the disruption, MBSB should seek to preserve at least 50% of normal peak-hour essential payment processing capacity and limit customers materially unable to complete essential payments to no more than 10% of the relevant active customer population.
No tolerance is proposed for knowingly executing payments with unverified authorisation, materially unreliable account balances or unresolved transaction integrity that could cause serious financial harm.
This statement combines duration, capacity, customer scope and financial integrity.
Validate it before formal adoption because MBSB has not provided actual transaction volumes, payment types, peak periods, customer characteristics, or recovery capabilities.
##### **Proposed Multidimensional Impact Tolerance Measures**
| **Impact Dimension** | **Illustrative Proposed Threshold** | **Rationale and Application** |
| --- | --- | --- |
| Maximum material disruption duration | Not more than 2 hours | Limits the period during which essential domestic payments cannot be completed at the required minimum capability. |
| Minimum essential payment processing capacity | At least 50% of normal peak-hour essential transaction throughput | Provides a provisional degraded-service boundary. Must be tested against actual transaction demand, queue behaviour and customer harm. |
| Affected customer population | No more than 10% of normally active payment customers materially unable to complete essential payments | Limits the reach of disruption, while requiring separate attention to vulnerable customers and high-consequence payment groups. |
| Payment processing latency | Essential payment requests should not experience more than 15 minutes of additional processing delay under degraded operation, where the applicable payment scheme permits this | Provides an early service-degradation indicator; any stricter payment-scheme or regulatory obligation takes precedence. |
| Transaction backlog | Essential payment backlog should remain within the amount that can be safely cleared before the approved harm boundary is exceeded | Avoids defining resilience solely by restoration of the application while large numbers of payments remain unprocessed. |
| Payment data integrity | No knowingly unverified, duplicate or incorrect payment execution where material financial harm may result | Establishes a financial-integrity constraint that can be breached without a prolonged outage. |
| Customer authorisation and fraud controls | No unauthorised relaxation of mandatory security, fraud or compliance controls | Prevents unsafe processing from being treated as successful service continuity. |
| Interbank and settlement obligations | No breach of applicable mandatory scheme or settlement obligations | Protects counterparties, financial infrastructure and regulatory obligations. |
| Regulatory obligations | No unapproved departure from applicable reporting, notification or payment-system requirements | Ensures resilience decisions remain within the bank's legal and supervisory obligations. |
| Restoration integrity | Normal processing should not resume until material transaction-state discrepancies are resolved or safely controlled | Prevents recovery actions from creating further customer harm. |
The suggested two-hour duration and associated percentages are not presented as a universal standard. They are starting hypotheses for a structured harm-calibration exercise.
In particular, 50% of peak throughput may be insufficient during salary-crediting periods, public holidays or other payment peaks.
Likewise, an outage affecting fewer than 10% of customers may still be intolerable if those customers cannot make essential payments.
##### **When Disruption Becomes Unacceptable**
For CBS-2, unacceptable harm should be considered to have occurred when any approved hard boundary is exceeded, not only when the maximum outage duration has elapsed.
Examples include:
- Customers' material inability to make essential domestic payments beyond the approved time or customer-impact limits.
- Significant incorrect account debits, duplicate payments or unverified beneficiary credits.
- Failure to meet applicable settlement or payment-system obligations.
- Widespread compromise of customer authorisation or payment integrity.
- Accumulating payment backlogs that cannot be cleared safely before serious customer harm arises.
- Prolonged disruption affecting other interconnected Critical Business Services.
Consequently, interpret overall Impact Tolerance as a set of related boundaries rather than a single two-hour recovery target.
##### **Illustrative Tolerance Consumption Example**
The following example shows how service impact can increase during a payment disruption. The figures are hypothetical and do not reflect MBSB's actual operating performance.
Illustrative CBS-2 customer impact during disruption
The customer-impact threshold is exceeded before the two-hour duration boundary.
■ Affected customers
■ Proposed ceiling
Illustrative scenario: the proposed 10% customer-impact ceiling is exceeded by 90 minutes, even though the two-hour duration boundary has not yet been reached.
This example demonstrates that an Impact Tolerance breach can occur before the maximum disruption duration.
#### **Calibrating and Approving the Impact Tolerance**
MBSB should not adopt the illustrative thresholds without undertaking a structured calibration exercise.
##### **Recommended Calibration Steps**
1\. Confirm the service boundary. Identify which domestic payment products, channels and customer outcomes are included in CBS-2, distinguishing internal transfers from interbank payments.
2\. Establish the harm baseline. Analyse historical transaction volumes, payment values, customer groups, peak periods, complaint trends, payment delays and previous disruptions.
3\. Identify time-sensitive customer outcomes. Examine essential retail payments, SME supplier obligations, corporate payments and other payment categories where delay can cause disproportionate harm.
4\. Evaluate interconnected services. Consider how CBS-1, CBS-3, CBS-6, CBS-7, CBS-8 and CBS-9 could be affected by common disruptions.
5\. Analyse the 24 Sub-CBS processes. Determine which processes must remain available, which can operate at reduced capacity and which may be temporarily deferred.
6\. Assess Cyber and ICT concentration risks. Evaluate dependencies on shared core banking, authentication, payment gateways, telecommunications, hosting, external payment infrastructure, and data integrity.
7\. Model harm against time and service degradation. Estimate when customer, financial, interbank and regulatory consequences become unacceptable.
8\. Test severe but plausible scenarios. Use scenario exercises and technical recovery tests to challenge the proposed thresholds.
9\. Obtain governance approval. Have the CBS Owner, Operational Resilience function, Operational Risk, Technology, Cybersecurity, Compliance and Senior Management review the recommendation and escalate approval through the bank's governance arrangements.
10\. Document the decision and review triggers. Retain the rationale, assumptions, evidence, approved limits, residual vulnerabilities and circumstances requiring reassessment.
##### **Recommended Approval and Evidence Register**
| Assessment Element | Responsible Function | Expected Evidence |
| --- | --- | --- |
| CBS-2 scope and customer outcomes | CBS Owner / Payment Operations | Approved service definition and process catalogue |
| Customer and transaction harm analysis | Payment Operations / Operational Risk | Transaction analysis, customer segmentation and harm assessment |
| Impact Tolerance proposal | CBS Owner / Operational Resilience | Documented tolerance proposal with assumptions and rationale |
| Cyber and ICT risk assessment | Technology / Cybersecurity / ICT Risk | Risk assessments, architecture reviews, vulnerability findings and concentration analysis |
| Recovery capability validation | BCM / Technology Recovery / Payment Operations | Recovery tests, failover evidence and transaction reconciliation results |
| External payment dependency assessment | Payment Operations / Third-Party Risk | Provider assurance, payment scheme requirements and contingency assessment |
| Regulatory alignment | Compliance / Regulatory Affairs | Applicable requirements assessment and identified obligations |
| Senior Management approval | Designated governance committee | Decision papers, approval minutes, challenge records and accepted residual risks |
| Continuous improvement | Operational Resilience / Risk Owners | Scenario findings, remediation register, retesting and periodic reassessment |
The approval record should distinguish between the level of disruption MBSB is prepared to tolerate and the level its current capabilities can withstand.
If testing shows that current capability falls short of the approved Impact Tolerance, the appropriate response is to identify and remediate the resilience gap. The tolerance should not simply be relaxed to match existing weaknesses.
#### **Applying the Impact Tolerance to Severe but Plausible Scenario Testing**
The approved Impact Tolerance should become the principal measure against which MBSB evaluates the resilience of CBS-2 under severe but plausible scenarios.
The scenarios should challenge both service availability and transaction integrity.
| Scenario | Sub-CBS Most Exposed | Principal Impact Tolerance Test | Evidence Required |
| --- | --- | --- | --- |
| Core banking outage during peak payment demand | CBS-2.5, 2.8, 2.10, 2.12, 2.15, 2.17 | Can essential payments continue within the approved customer, capacity and duration boundaries? | End-to-end recovery results, payment throughput, affected-customer analysis and reconciliation. |
| Authentication failure combined with DDoS attack | CBS-2.1, 2.4, 2.16, 2.22 | Can customers safely authorise payments through available channels without weakening controls? | Authentication failover, DDoS exercise, customer-impact data and control assurance. |
| External interbank payment network outage | CBS-2.11, 2.13–2.15, 2.19–2.20 | Can MBSB manage payment queues, essential obligations and customer harm while the external network is unavailable? | Network exercise reports, backlog analysis, scheme coordination and communication records. |
| Ransomware with ledger data corruption | CBS-2.8, 2.10, 2.12, 2.17–2.18, 2.24 | Can trusted transaction states be recovered without duplicate, missing or incorrect payments? | Cyber recovery results, immutable record validation, reconciliation and controlled restoration approvals. |
| Simultaneous primary and recovery infrastructure failure | CBS-2.9–2.15, 2.22–2.24 | Are alternative arrangements sufficiently independent to preserve minimum payment capability? | Infrastructure dependency review, recovery-site tests, third-party evidence and scenario results. |
| Payment gateway capacity exhaustion and specialist staffing shortage | CBS-2.9, 2.11, 2.19–2.24 | Can the bank sustain minimum payment capacity and control backlog growth during a prolonged disruption? | Load testing, staffing exercises, operational capacity reports and backlog clearance results. |
Testing should measure the time required to restore verified customer payment outcomes, not merely the time required to restart a platform.
A scenario should also record when each harm threshold was approached or exceeded, the effectiveness of management decisions, the performance of third parties and whether remediation is necessary.
#### **Management Actions and Continuous Resilience Improvement**
Once the Impact Tolerance is approved, MBSB should use it to prioritise investments and management actions according to their ability to reduce unacceptable harm.
The highest-priority areas likely include core banking and ledger integrity, customer authentication, domestic interbank payment connectivity, transaction reconciliation, cyber recovery, alternative processing, and coordinated restoration.
Management should receive regular reporting on the following matters:
- The approved CBS-2 Impact Tolerance and the supporting harm indicators.
- Actual service performance and material disruptions.
- Sub-CBS processes whose recovery capability is insufficient to support the tolerance.
- Shared technology and third-party concentration risks.
- Severe but plausible scenario test outcomes.
- Material vulnerabilities, remediation owners and due dates.
- Outstanding risk acceptances and their rationale.
- Changes in transaction demand, customer exposure and regulatory obligations.
Do not treat risk acceptance as evidence that the service is resilient. Where a material gap remains, management should understand its potential customer consequences and approve a time-bound remediation plan.
Reassess the Impact Tolerance after significant changes in payment volumes, customer behaviour, technology architecture, external payment infrastructure, service providers, cyber threats, or applicable regulatory requirements.
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Establishing an Impact Tolerance for CBS-2: Domestic Funds Transfer and Payment Services gives MBSB a clear boundary for determining when operational disruption causes unacceptable harm to customers, counterparties, financial infrastructure, or the bank.
The assessment of all 24 Sub-CBS processes demonstrates that domestic payment resilience depends on the combined performance of customer channels, authentication, account validation, fraud controls, payment processing, interbank connectivity, settlement coordination, reconciliation, monitoring and recovery arrangements.
Failure of a single critical process may interrupt service, while simultaneous failures across shared resources can accelerate customer harm and push the overall service beyond its approved tolerance.
Integrating Cyber and ICT Risks into the assessment strengthens MBSB's understanding of how ransomware, data corruption, authentication compromise, telecommunications outages, infrastructure failures and technology concentration can affect end-to-end payment delivery.
It also establishes the preventive, detective, response, recovery and resilience controls required to reduce the likelihood and consequences of disruption.
The proposed two-hour maximum material disruption duration, 50% minimum essential processing capacity and 10% affected-customer ceiling are illustrative calibration assumptions only.
They must be validated against MBSB's actual payment operations, customer-harm analysis, regulatory obligations and demonstrated recovery capability.
Material financial-integrity failures or serious customer harm may breach the approved tolerance regardless of duration.
By linking the Impact Tolerance to auditable risk management evidence, scenario testing, recovery validation, remediation, and management oversight, MBSB can move beyond a narrow focus on system recovery to demonstrate that essential domestic payment outcomes remain protected during severe operational disruption.
The Impact Tolerance should ultimately serve as a practical management boundary guiding resilience investment, recovery priorities, operational decision-making and continuous improvement.
The central principle is that CBS-2 is resilient only when MBSB can demonstrate that domestic payment services remain within acceptable limits of customer, financial and operational harm—even when significant Cyber, ICT or external infrastructure disruptions occur.
##### **References (Notes from the Author)**
The assessment draws on the BNM Operational Resilience Discussion Paper (19 December 2025), which discusses critical services, disruption tolerances, interdependencies, severe but plausible scenario testing, and governance.
The methodological structure also draws on BCM Institute's What is Impact Tolerance in Operational Resilience?, Categorising Levels of Harm for Impact Tolerance and Introduction to Impact Tolerance.
All numerical thresholds and MBSB-specific process assessments in this chapter are illustrative recommendations requiring organisational validation.
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| **eBook 3: Starting Your OR Implementation** | | | | |
| --- | --- | --- | --- | --- |
| **CBS-2 Domestic Funds Transfer and Payment Services** | | | | |
| **CBS-2 DP** | **CBS-2 MII** | **CBS-2 ITo** | **CBS-2 SbPS** | **CBS-2 ST** |
| [![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[DP\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/6061bf66-5bbb-4d60-bf93-b90415e0c94c.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/6061bf66-5bbb-4d60-bf93-b90415e0c94c) | [![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[MII\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/44087c85-3c98-4d94-997a-4891ee09baff.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/44087c85-3c98-4d94-997a-4891ee09baff) | [![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[ITo\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/e124bae1-4ad4-4c27-8400-1fe1d67fbea9.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/e124bae1-4ad4-4c27-8400-1fe1d67fbea9) | [![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[SbPS\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/9ec97fec-0ab6-45a6-bbbe-f76f4303ad2f.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/9ec97fec-0ab6-45a6-bbbe-f76f4303ad2f) | [![\[OR\] \[MBSB\] \[E3\] \[CBS\] \[2\] \[ST\] Domestic Funds Transfer and Payment Services](https://no-cache.hubspot.com/cta/default/3893111/bd69c69a-27ca-4958-b8ed-88616906ad6f.png)](https://cta-redirect.hubspot.com/cta/redirect/3893111/bd69c69a-27ca-4958-b8ed-88616906ad6f) |
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