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Building Resilient Banking Operations: The Metrobank Operational Resilience Implementation Guide
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[OR] [MBT] [E3] [CBS] [12] [ITo] Establish Impact Tolerances

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Establishing impact tolerances is a core requirement of Operational Resilience, ensuring that Metrobank can continue to deliver critical business services within acceptable disruption thresholds, even when supported by third parties or outsourced arrangements. 

For CBS-12 Third-Party / Outsourced Service Management, impact tolerances define the maximum level of disruption that Metrobank can tolerate before causing intolerable harm to customers, breaching regulatory obligations, or undermining market confidence.

In line with regulatory expectations and the principles outlined in “What is Impact Tolerance in Operational Resilience, impact tolerances are expressed through outcome-focused measures such as Maximum Tolerable Downtime (MTD) and Maximum Tolerable Data Loss (MTDL), rather than traditional recovery objectives. 

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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New call-to-actionCBS-12 Third-Party / Outsourced Service Management

[OR] [MBT] [E3] [CBS] [12] [ITo] Establish Impact TolerancesEstablishing impact tolerances is a core requirement of Operational Resilience, ensuring that Metrobank can continue to deliver critical business services within acceptable disruption thresholds, even when supported by third parties or outsourced arrangements. 

For CBS-12 Third-Party / Outsourced Service Management, impact tolerances define the maximum level of disruption that Metrobank can tolerate before causing intolerable harm to customers, breaching regulatory obligations, or undermining market confidence.

In line with regulatory expectations and the principles outlined in “What is Impact Tolerance in Operational Resilience, impact tolerances are expressed through outcome-focused measures such as Maximum Tolerable Downtime (MTD) and Maximum Tolerable Data Loss (MTDL), rather than traditional recovery objectives. 

These tolerances reflect Metrobank’s risk appetite, the criticality of third-party dependencies, and the potential systemic impact of prolonged disruption.

Banner [Table] [OR] [E3] Establish Impact Tolerance

Table P4: Establish Impact Tolerance for CBS-12

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

12.1

Vendor Risk Management

72 hours

No data loss tolerated

Indirect service degradation due to delayed risk assessments and onboarding

Potential non-compliance with BSP third-party risk management guidelines

Operational / Regulatory

Generally adequate, periodic reviews in place

Enhance automation of vendor risk assessments and increase frequency for critical vendors

12.2

Third-Party Contract Management

48 hours

Minimal loss (≤ 4 hours of contract updates)

Delays in enforcing SLAs and contractual protections

Risk of contractual and regulatory breaches

Legal / Regulatory

Moderate, reliant on manual processes

Digitise contract repositories and improve version control

12.3

Outsourced Service Monitoring

24 hours

No data loss tolerated

Delayed detection of service degradation affecting customer-facing services

Heightened supervisory concern if issues go undetected

Operational / Reputational

Strong for key vendors, weaker for non-critical ones

Expand real-time monitoring coverage to all material outsourced services

12.4

Service Continuity Planning

24 hours

No data loss tolerated

Prolonged service disruption during third-party incidents

Breach of operational resilience and outsourcing requirements

Operational / Systemic

Partially mature, uneven across vendors

Standardise continuity requirements and conduct joint resilience testing

12.5

Compliance and Regulatory Assurance

48 hours

No data loss tolerated

Limited immediate customer impact

High risk of regulatory findings or penalties

Regulatory

Adequate but resource-dependent

Strengthen compliance tracking tools and independent assurance reviews

12.6

Incident Management and Response

12 hours

No data loss tolerated

Rapid escalation of customer harm if incidents are not managed promptly

Immediate regulatory scrutiny for major incidents

Operational / Reputational

Strong for critical incidents, improving for minor ones

Enhance third-party incident reporting timelines and escalation protocols

 
Banner [Summing] [OR] [E3] Establish Impact Tolerance

The establishment of clear and proportionate impact tolerances for CBS-12 Third-Party / Outsourced Service Management enables Metrobank to move beyond traditional recovery metrics and focus on preventing intolerable harm.

By defining outcome-based thresholds for downtime, data loss, and regulatory exposure, Metrobank strengthens its ability to manage systemic risks arising from third-party dependencies.

The assessment highlights that while core controls and governance structures are largely in place, resilience can be further enhanced through greater automation, standardisation of third-party continuity expectations, and expanded monitoring of outsourced services.

Ongoing scenario testing against these impact tolerances will ensure they remain credible, actionable, and aligned with Metrobank’s evolving business model and regulatory landscape.

Overall, this approach supports a proactive, customer-centric, and regulator-ready Operational Resilience posture, reinforcing Metrobank’s ability to withstand, adapt to, and recover from disruptions within its third-party ecosystem.

Building Resilient Banking Operations: The Metrobank Operational Resilience Implementation Guide

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CBS-12 Third-Party / Outsourced Service Management
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