CBS-11 Overseas Remittance and Foreign Exchange Services
In operational resilience, scenario testing is a critical process used to evaluate how well a business service can withstand extreme but plausible disruptions, ensuring its continuity and compliance with regulatory requirements.
For Metrobank's CBS-11 Regulatory and Compliance Reporting, scenario testing should encompass a wide range of scenarios that challenge both the processes and resources that underpin its critical business services.
This testing will help identify vulnerabilities in the reporting framework, compliance monitoring, report submission, risk assessment, and the systems that support regulatory reporting.
The focus is to assess how each component responds to potential disruptions and to verify the robustness of the associated risk mitigation actions.
The testing should also consider integrating cyber and ICT risks, ensuring the continuity of the reporting mechanisms, even in the face of digital threats or failures.
Table P6: Perform Scenario Testing for CBS-11
|
Sub-CBS Code |
Sub-CBS |
Recommended Scenario Test Themes |
Impact/Effect |
Evidence of Proactive Risk Management Action |
|
11.1 |
Regulatory Reporting Framework |
1. Regulatory changes with insufficient lead time 2. Failure to align with new compliance regulations 3. Major regulatory body inspection failure |
Delays in compliance submissions Regulatory fines Loss of trust |
- Regular reviews of regulatory changes - Dedicated regulatory change management process |
|
11.2 |
Compliance Monitoring and Auditing |
1. System failure during internal audit 2. Inaccurate audit data from third parties 3. Manual audit process errors |
Inaccurate audit results Delayed compliance assessments Operational risks |
- Automated auditing tools - Cross-verification procedures - Regular training of audit teams |
|
11.3 |
Submission of Regulatory Reports |
1. Cyberattack on the report submission system 2. Human error in data entry or report formatting 3. Network outage during submission deadline |
Non-compliance penalties Legal consequences Reputational damage |
- Regular backup systems - Error-proofing mechanisms in report submission - Crisis communication plans |
|
11.4 |
Risk Assessment and Mitigation in Reporting |
1. Unforeseen external risk factor affecting reporting integrity 2. Misalignment in risk appetite and reporting thresholds 3. Inadequate risk impact analysis |
Financial losses Non-compliance Reputational risk |
- Real-time risk monitoring systems - Clear risk appetite definitions - Regular stress testing of risk management models |
|
11.5 |
Reporting Systems and Technology |
1. System downtime during peak reporting periods 2. Data breach or unauthorized access 3. Inability to integrate with external regulatory systems |
Data integrity breaches Disruption in reporting timelines Financial losses |
- Robust cybersecurity measures - System redundancy and failover - Regular security audits and penetration testing |
Integration of Cyber and ICT Risks
In today's digital landscape, cyber and ICT risks are becoming increasingly relevant in scenario testing for regulatory and compliance reporting purposes.
The integration of these risks ensures that Metrobank’s critical reporting systems can withstand potential cyber threats, including data breaches, ransomware attacks, and system failures.
Testing scenarios should incorporate the possible impacts of these risks on the integrity, confidentiality, and availability of data, as well as the ability to maintain operations under such threats.
Scenario testing for Metrobank’s CBS-11 Regulatory and Compliance Reporting is essential for understanding and preparing for disruptions that may challenge the bank's ability to meet regulatory obligations.
Through proactive risk management and the integration of cyber and ICT risks, Metrobank can safeguard its reporting capabilities and mitigate the potential impacts of operational disruptions.
These tests not only ensure compliance but also build trust with regulatory bodies and the public, demonstrating a commitment to operational resilience and robust risk management.
Gain Competency: For organisations looking to accelerate their journey, BCM Institute’s training and certification programs, including the OR-5000 Operational Resilience Expert Implementer course, provide in-depth insights and practical toolkits for effectively embedding this model.





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