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[OR] [MBT] [E3] [CBS] [11] [ITo] Establish Impact Tolerances

Written by Moh Heng Goh | Dec 3, 2025 6:19:30 AM

CBS-11 Overseas Remittance and Foreign Exchange Services

In the context of operational resilience, setting appropriate impact tolerances is a critical step to ensure that Metrobank’s critical business services (CBS), particularly CBS-11 Regulatory and Compliance Reporting, can withstand and recover from disruptions.

Impact tolerance refers to the maximum time that a process or service can be disrupted before it results in unacceptable consequences, whether operational, regulatory, or reputational.

It also includes the maximum data loss that is acceptable during such disruptions.

This chapter provides a detailed analysis of the impact tolerances for each of the sub-critical business services (Sub-CBS) under CBS-11, ensuring compliance with regulatory standards while maintaining operational effectiveness.

The goal is to establish resilience benchmarks for each sub-service, allowing Metrobank to monitor and manage risks proactively.

Table P4: Establish Impact Tolerance for CBS-11

 

Sub-CBS Code

Sub-CBS

Maximum Tolerable Downtime (MTD)

Maximum Tolerable Data Loss (MTDL)

Customer Impact

Regulatory Impact

Impact Type

Current Resilience Status

Action Required

11.1

Regulatory Reporting Framework

4 hours

1 day

Moderate disruption to service continuity for customers relying on accurate regulatory information

Non-compliance with regulatory reporting timelines can lead to fines or penalties

Operational, Regulatory

Resilient, but requires monitoring

Enhance the reporting system resilience and ensure failover procedures are in place

11.2

Compliance Monitoring and Auditing

6 hours

1 day

Low disruption to customer services, but reduced assurance of compliance

Regulatory breach due to delayed monitoring or auditing processes

Operational, Regulatory

Satisfactory, but periodic testing required

Implement real-time monitoring capabilities and ensure automated alerts for potential failures

11.3

Submission of Regulatory Reports

2 hours

12 hours

No direct customer impact, but delayed reporting could affect service timelines

Regulatory non-compliance due to the late submission of mandatory reports

Regulatory

Resilient, with regular system checks

Optimize the submission process with contingency procedures and alternative methods

11.4

Risk Assessment and Mitigation in Reporting

8 hours

1 day

Potential indirect impact on customer trust and business reputation

Regulatory failure in assessing and mitigating risks may result in penalties or forced shutdowns

Operational, Regulatory

Needs improvement: Incident response protocols are not fully defined

Strengthen risk mitigation strategies, review risk assessment timelines

11.5

Reporting Systems and Technology

4 hours

6 hours

Low customer impact, but delays may affect internal compliance processes

System failure may prevent timely reporting, leading to regulatory fines or sanctions

Operational, Regulatory

Stable, though dependent on external technology vendors

Build system redundancies and conduct regular stress tests to validate technology resilience

 
 
 

Establishing and monitoring impact tolerances for CBS-11 Regulatory and Compliance Reporting is essential to maintaining Metrobank’s operational resilience.

By defining clear tolerances for downtime and data loss, the bank can ensure that it meets regulatory requirements, minimises customer disruptions, and avoids significant financial penalties.

Ongoing resilience assessments, including routine system testing and risk mitigation exercises, will further enhance Metrobank’s ability to withstand disruptions and ensure continued compliance.

This approach will position Metrobank to manage risk more effectively, supporting long-term stability in the face of potential operational challenges.

 

Building Resilient Banking Operations: The Metrobank Operational Resilience Implementation Guide

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CBS-11 Regulatory and Compliance Reporting
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