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Building Organisational Resilience: An Operational Resilience Guide for Malaysian Life Reinsurance
OR BB FI MY Gen-14

[OR] [MLRE] [E3] [CBS] [2] [ITo] Establish Impact Tolerances

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Operational resilience requires financial institutions to define the level of disruption they can tolerate for each Critical Business Service (CBS) before causing intolerable harm to customers, counterparties, financial stability, or regulatory standing.

In line with the expectations outlined in the 2025 Discussion Paper on Operational Resilience by Bank Negara Malaysia (BNM), impact tolerance must be expressed in measurable terms such as time, volume, data loss, and service degradation thresholds.

For CBS-2 Claims Processing & Settlement, the ability to process and settle claims accurately and promptly is central to maintaining cedant trust, meeting contractual obligations, and safeguarding market confidence.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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Introduction

[OR] [MLRE] [E3] [CBS] [2] [ITo] Establish Impact Tolerances

Operational resilience requires financial institutions to define the level of disruption they can tolerate for each Critical Business Service (CBS) before causing intolerable harm to customers, counterparties, financial stability, or regulatory standing.

In line with the expectations outlined in the 2025 Discussion Paper on Operational Resilience by Bank Negara Malaysia (BNM), impact tolerance must be expressed in measurable terms such as time, volume, data loss, and service degradation thresholds.

For CBS-2 Claims Processing & Settlement, the ability to process and settle claims accurately and promptly is central to maintaining cedant trust, meeting contractual obligations, and safeguarding market confidence.

Disruptions to this CBS may result in financial loss to cedants, reputational erosion, regulatory breaches, and systemic confidence risk—particularly during catastrophe events or high-volume mortality scenarios.

This chapter defines appropriate impact tolerances for each Sub-CBS within CBS-2, translating operational resilience principles into measurable thresholds such as Maximum Tolerable Downtime (MTD) and Maximum Tolerable Data Loss (MTDL), together with qualitative customer and regulatory impact considerations.

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

Table P4: Establish Impact Tolerance for CBS-2 

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

2.1

Claim Notification & Receipt

24 hours

Near-zero (≤15 minutes transactional data)

Delay in claim registration; cedant dissatisfaction

Breach of service standards and reporting timelines

Operational / Reputational

Moderate – manual fallback exists

Enhance automated intake redundancy and offsite replication

2.2

Document & Data Verification

48 hours

≤1 hour

Slower validation; backlog accumulation

Risk of inaccurate regulatory data submission

Operational / Compliance

Moderate

Implement workflow prioritisation and digital document repository DR

2.3

Preliminary Assessment & Triage

48 hours

≤1 hour

Delayed classification of urgent claims (e.g., catastrophe events)

Supervisory concern during systemic events

Operational / Prudential

Moderate

Define catastrophe surge protocol and alternate-site capability

2.4

Detailed Claims Assessment

3 working days

≤4 hours

Financial uncertainty for cedants; potential liquidity strain

Risk of delayed settlement affecting solvency reporting

Financial / Compliance

Developing

Strengthen remote access and specialist cross-training

2.5

Third-Party Engagement & Investigation

5 working days

≤1 day (documentation records)

Delay in complex claim resolution

Limited direct regulatory breach but reputational exposure

Operational / Reputational

Moderate

Formalise alternate vendor panel and SLA resilience testing

2.6

Claims Decisioning & Approval

48 hours

≤1 hour

Delayed approval; cedant dissatisfaction

Breach of contractual and governance standards

Governance / Compliance

Strong core controls

Implement dual-site approval workflow and delegated authority backup

2.7

Settlement Calculation & Fund Disbursement

24 hours (post-approval)

Near-zero (≤15 minutes of financial records)

Direct financial impact to cedants; liquidity and trust erosion

High – potential breach of prudential and payment system requirements

Financial / Systemic

Strong but dependent on payment systems

Test alternate banking channels and payment contingency procedures

2.8

Claim Communication & Reporting

48 hours

≤4 hours

Reduced transparency; reputational damage

Breach of regulatory disclosure timelines

Reputational / Compliance

Moderate

Implement automated communication templates and backup communication channels

2.9

Record Archival & Compliance Reporting

5 working days

Zero tolerance for permanent loss

Risk of audit findings; inability to evidence decisions

High – statutory record retention breach

Compliance / Legal

Moderate

Enhance immutable backup storage and periodic restoration testing

2.10

Continuous Improvement & Analytics

10 working days

≤1 day

Limited short-term customer impact

Low immediate regulatory risk

Strategic / Governance

Developing

Improve data warehouse resilience and analytics backup capability

Alignment with 2025 BNM Operational Resilience Expectations

The tolerances above reflect principles emphasised in the 2025 BNM Discussion Paper, including:

  • Defining impact tolerance based on intolerable harm, not internal recovery targets.
  • Considering both time-based and data integrity-based tolerances.
  • Addressing systemic stress scenarios, such as pandemic mortality spikes or catastrophe claims surges.
  • Recognising financial system confidence and cedant liquidity as impact dimensions.
  • Ensuring board oversight and periodic review of tolerance calibration.

For example:

  • Settlement disbursement (Sub-CBS 2.7) carries a shorter MTD due to direct financial and liquidity implications.
  • Record archival (Sub-CBS 2.9) carries zero tolerance for permanent data loss due to statutory compliance requirements.
  • Continuous improvement (Sub-CBS 2.10) has a longer tolerance because it does not create immediate intolerable harm.
 

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

Establishing impact tolerances for CBS-2 Claims Processing & Settlement provides Malaysian Life Reinsurance with a measurable boundary between acceptable disruption and intolerable harm. By defining explicit MTD and MTDL thresholds for each Sub-CBS, the organisation can:

  • Prioritise resilience investment based on the severity of impact.
  • Design scenario testing aligned with severe but plausible disruptions.
  • Strengthen board-level oversight of operational resilience.
  • Demonstrate compliance with BNM’s evolving operational resilience expectations.

Impact tolerance is not static. It must be reviewed periodically in light of business growth, digital transformation, outsourcing dependencies, and emerging systemic risks.

For a reinsurer whose credibility depends on timely and accurate claims settlement, maintaining resilience within these defined tolerances is fundamental to sustaining market confidence and long-term stability.

 

Building Organisational Resilience: An Operational Resilience Guide for Malaysian Life Reinsurance

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