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Strengthening Operational Resilience in the Philippine Bank of Communications
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[OR] [PBCOM] [E3] [CBS] [1] [MD] Map Dependency

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For CBS-1 Deposit and Account Services, dependency mapping should show how the service is delivered end to end, from customer initiation through processing, posting, access, monitoring, reporting, and recovery.

BCM Institute’s mapping guidance describes this as identifying the interconnections and interdependencies among people, processes, technology, facilities, information, and third-party service providers so that weaknesses and concentration risks can be understood before a disruption occurs.

BSP Circular No. 1203 takes the same direction for Philippine BSFIs: it expects banks to map critical operations end-to-end, identify the key resources that keep them running, and understand the dependencies that can affect service delivery during disruption.

For The Philippine Bank of Communications (PBCom), a practical dependency map for Deposit and Account Services should reflect the bank’s public operating channels, including account opening, branch and ATM access, mobile banking, access to funds via POP, and card control capabilities.

These public touchpoints strongly suggest that PBCom’s deposit service is delivered through an interconnected operating model spanning branch operations, customer servicing, compliance controls, digital channels, cards/ATM services, and supporting partners.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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New call-to-actionCBS-1 Deposit & Account Services

Introduction

[OR] [PBCOM] [E3] [CBS] [1] [MD] Map Dependency

For CBS-1 Deposit and Account Services, the dependency mapping should show how the service is delivered end-to-end, from customer initiation through processing, posting, access, monitoring, reporting, and recovery.

BCM Institute’s mapping guidance describes this as identifying the interconnections and interdependencies among people, processes, technology, facilities, information, and third-party service providers so that weaknesses and concentration risks can be understood before a disruption occurs.

BSP Circular No. 1203 takes the same direction for Philippine BSFIs: it expects banks to map critical operations end-to-end, identify the key resources that keep them running, and understand the dependencies that can affect service delivery during disruption.

For The Philippine Bank of Communications (PBCom), a practical dependency map for Deposit and Account Services should reflect the bank’s public operating channels, including account opening, branch and ATM access, mobile banking, access to funds via POP, and card control capabilities.

These public touchpoints strongly suggest that PBCom’s deposit service is delivered through an interconnected operating model spanning branch operations, customer servicing, compliance controls, digital channels, cards/ATM services, and supporting partners.

The table below is therefore a recommended operational resilience mapping model for PBCom’s CBS-1, not a claim about undisclosed internal system architecture.

Banner [Table] [OR] [E3] Map Dependency

Table P2: Map Dependency for CBS-1

Sub-CBS Code

Sub-CBS

Dependency Type

Dependency Detail (What/ Who is involved)

Connectivity (How it connects/ interacts with the CBS or other components)

1.1

Customer Onboarding and Account Application

People

Branch sales officers, customer service officers, relationship managers, and contact centre staff

Frontline staff initiates the deposit service by capturing customer intent, product choice, and application data for downstream KYC, approval, and account creation.

   

Process

Account opening workflow, product selection, document capture, consent taking, and initial screening

Serves as the entry point to CBS-1 and feeds data to KYC/CDD, approval, account setup, and channel enablement.

   

Technology

Branch onboarding platform, digital account opening interface, document imaging, CRM/workflow tools

Captures application records and transmits them to compliance review, CIF creation, and core deposit processing.

   

Third Party

ID verification utilities, courier/document delivery support, telecom/network providers

Supports remote or assisted onboarding and ensures documents, connectivity, and external validations are available.

1.2

Customer Identification and Verification (KYC/CDD)

People

Compliance officers, branch operations staff, AML analysts, and onboarding reviewers

Validate identity, customer risk profile, and documentary completeness before the account can be opened.

   

Process

KYC, CDD, sanctions screening, watchlist checks, beneficial ownership validation, customer risk rating

Controls whether onboarding may proceed, be escalated, or be rejected; directly affects account approval and regulatory compliance.

   

Technology

KYC screening tools, AML systems, customer master file, document repository

Receives customer data from onboarding and returns risk/clearance status to account approval and monitoring teams.

   

Third Party

External screening databases, government/industry verification sources

Provides independent validation and screening inputs that strengthen regulatory compliance and fraud prevention.

1.3

Account Approval and Opening

People

Branch approvers, operations supervisors, compliance signatories, maker-checker reviewers

Authorise the opening decision and ensure account controls, customer class, and approval limits are applied properly.

   

Process

Maker-checker approval, CIF creation, account number generation, product assignment

Converts a validated application into a live account and triggers initial funding, statements, and channel setup.

   

Technology

Core banking/CASA platform, customer information file system, workflow engine

Creates the official deposit account record that all later transactions, balances, fees, and reporting depend on.

   

Third Party

Network/service providers supporting connectivity or e-sign workflows

Enable continuity of approval and account activation where remote or electronic processing is used.

1.4

Initial Funding and Deposit Booking

People

Tellers, branch operations, treasury settlement support, and customer service staff

Accept and validate initial cash, check, transfer, or clearing-based funding of newly opened accounts.

   

Process

Cash receipt, check acceptance, transfer posting, float/hold rules, booking, and validation

Activates the account economically and links onboarding to balance availability, reconciliation, and fraud controls.

   

Technology

Teller platform, cash transaction system, core banking ledger, clearing/payment interfaces

Post opening balances to the account and update available versus ledger balances for downstream use.

   

Third Party

Payment/clearing rails, correspondent institutions, armoured cash/logistics support

External settlement and cash-handling services affect when funds become available and how exceptions are resolved.

1.5

Product Setup and Account Parameter Maintenance

People

Product management, deposit operations, system administrators, and branch operations control

Maintain account features, limits, dormancy rules, interest basis, fee structures, and control parameters.

   

Process

Product configuration, parameter maintenance, limit setting, and authorisation matrix updates

Provides the set of rules that govern account behaviour across transactions, fees, restrictions, and reporting.

   

Technology

Product table configuration in core banking, parameter libraries, and change control tools

Drives system behaviour for all downstream processing, including postings, charges, statements, and restrictions.

   

Third Party

Vendors supporting core banking configuration or managed application services

Changes by service providers may affect account functionality, making change governance and rollback capability critical.

1.6

Deposit Transactions Processing

People

Tellers, branch operations, back-office operations, transaction monitoring staff

Execute and supervise routine deposits, credits, transfers, and ledger updates for customer accounts.

   

Process

Deposit posting, batch and real-time transaction processing, exception routing, and end-of-day balancing

Forms the daily operating backbone of CBS-1 and feeds balances, statements, fraud rules, and reconciliation.

   

Technology

Core banking engine, teller system, digital channel interface, transaction switch, middleware

Moves transactions between customer channels and the official deposit ledger in near real time or scheduled batches.

   

Third Party

Payment processors, telecom/network providers, and outsourced operations support were used

External connectivity or processor failure can delay posting, create backlogs, or increase manual workarounds.

1.7

Withdrawal and Funds Access Processing

People

Tellers, branch cash custodians, ATM support teams, and branch approvers

Facilitate over-the-counter withdrawals and controlled access to customer funds.

   

Process

Cash withdrawal workflow, signature/credential validation, balance verification, hold checking

Connects customer access requests to balance controls, fraud checks, and channel authorisation logic.

   

Technology

Teller application, core banking balance engine, ATM/switch interface, channel authentication tools

Confirms the available balance and restrictions before granting cash or debit access.

   

Third Party

ATM network operators, cash logistics providers, telecom providers

Support customer access outside the branch and affect availability during outages or cash shortages.

1.8

Account Servicing and Customer Maintenance

People

Branch service teams, call centre, and back-office maintenance staff

Handle changes to customer information, account status, contact details, and service requests.

   

Process

Customer data maintenance, account update workflow, request verification, and audit trail logging

Keeps customer and account records accurate, ensuring statements, alerts, access rights, and compliance records remain reliable.

   

Technology

CRM, customer master maintenance tools, imaging/archive system, service request workflow

Synchronises updates across customer records, digital channels, cards, and reporting systems.

   

Third Party

Messaging providers, document fulfilment vendors

Support the delivery of notices, confirmations, and requested servicing outputs to customers.

1.9

Interest, Fees, and Charges Processing

People

Product operations, finance, deposit operations control, and system support

Oversee rate changes, fee application logic, exception handling, and customer adjustments.

   

Process

Interest accrual, capitalisation, service charge computation, waiver, and reversal control

Affects customer balances, product profitability, complaint handling, and financial reporting.

   

Technology

Core deposit engine, batch scheduler, rate tables, and fee configuration modules

Calculates and posts recurring credits/debits based on product parameters and account activity.

   

Third Party

Vendors supporting rate feeds or managed application support

External support issues can delay scheduled runs or require manual compensating adjustments.

1.10

Statement, Passbook, and Balance Reporting

People

Branch staff, operations reporting teams, customer service, print/mail support

Produce and respond to customer requests for balances, statements, and transaction history.

   

Process

Statement generation, passbook update, report extraction, customer balance inquiry, and servicing

Converts posted transaction data into customer-facing records and evidence for disputes and audits.

   

Technology

Statement engine, passbook printer/update devices, online balance inquiry tools, and archive repository

Pulls data from core banking and delivers it to branches, mobile channels, or printed output.

   

Third Party

Print and mail vendors, SMS/email notification providers

Influence the timeliness and availability of customer communications and the delivery of physical statements.

1.11

Digital Account Access Enablement

People

Digital banking operations, branch onboarding staff, customer support, and IT access administrators

Enrol customers into mobile/online access and resolve activation issues.

   

Process

User registration, credential issuance, device binding, OTP/authentication setup, channel enrollment

Extends CBS-1 delivery beyond branches and links deposit accounts to self-service access.

   

Technology

Mobile banking platform, online banking gateway, IAM/authentication services, API/middleware layer

Connects live deposit accounts to PBCom’s digital channels and customer self-service functions.

   

Third Party

OTP/SMS providers, authentication vendors, cloud or managed hosting services were used

Failure here can prevent login, enrollment, or secure transaction authorisation even if the core account remains available.

1.12

ATM and Card-Based Access Management

People

Card operations, ATM support teams, fraud staff, and branch customer service

Issue, replace, block, and monitor debit card access associated with deposit accounts.

   

Process

Card issuance, PIN management, activation, blocking, replacement, and limit maintenance

Provides a customer-access route to deposit balances and interacts with fraud monitoring and complaint handling.

   

Technology

Card management system, ATM switch, PIN/authentication controls, card-control platform

Links the deposit account to card credentials and ATM channel transactions.

   

Third Party

Card personalisation vendors, network schemes, and ATM service providers

External partners affect issuance turnaround, authorisation routing, and channel uptime.

1.13

Account Reconciliation and Exception Handling

People

Operations control, finance, branch operations, settlement, and recon analysts

Review unmatched items, breaks, suspense entries, and posting discrepancies.

   

Process

Daily balancing, suspense management, transaction investigation, correction, and adjustment workflow

Restores ledger integrity and ensures that downstream statements, fees, and regulatory records are accurate.

   

Technology

Reconciliation tools, core ledger reports, exception queues, and settlement matching utilities

Compare branch, channel, switch, and ledger records to identify breaks that require remediation.

   

Third Party

External clearing/switch reports, vendor-managed recon platforms

Third-party data feeds are needed to validate end-to-end completeness and timing of transaction records.

1.14

Dormancy, Holds, and Account Restrictions Management

People

Compliance, branch operations, legal support, and deposit operations control

Decide and administer restrictions such as holds, freezes, dormancy controls, and release actions.

   

Process

Dormancy tagging, hold placement, lien/restriction maintenance, release/override approval

Protects the bank and customers by controlling access based on legal, compliance, or inactivity conditions.

   

Technology

Core banking restriction codes, case management tools, and customer master controls

Restriction flags interact with withdrawals, digital access, card usage, and account servicing.

   

Third Party

External legal notices, law enforcement/judicial communications, outsourced records support

External instructions may trigger holds or releases, thereby affecting account availability.

1.15

Fraud Monitoring and Transaction Surveillance

People

Fraud analysts, AML monitoring teams, security operations, and branch escalation contacts

Monitor unusual account activity and coordinate controls, blocking, investigation, and escalation.

   

Process

Fraud rule monitoring, alert triage, customer confirmation, temporary blocking, and investigation workflow

Protects CBS-1 from losses and customer harm while addressing restrictions, complaints, and regulatory reporting.

   

Technology

Fraud monitoring engine, AML surveillance, card/channel monitoring tools, case management

Consumes transaction and channel data from deposit, ATM, and digital systems to identify anomalous behaviour.

   

Third Party

Fraud intelligence feeds, card network alerts, and managed security providers were used

External threat indicators improve the detection of broader attack campaigns and compromised credentials.

1.16

Complaints, Disputes, and Service Recovery

People

Contact centre, branch service teams, dispute resolution officers, operations managers

Receive complaints, investigate disputes, and implement service correction or goodwill remedies.

   

Process

Case intake, investigation, turnaround tracking, customer communication, corrective posting, or reversal

Links failures in any Sub-CBS back to customer impact and reputational recovery.

   

Technology

CRM/case management, call centre systems, complaint tracking tools, evidence archive

Aggregates transaction, statement, fraud, and channel information needed to resolve issues end-to-end.

   

Third Party

Network partners, card processors, print/mail, or messaging providers

Third-party evidence and response timing often determine the speed and completeness of resolution.

1.17

Regulatory Reporting and Compliance Monitoring

People

Compliance, AML officers, regulatory reporting teams, and senior management oversight

Monitor adherence to rules and prepare required returns, issue escalations, and management reporting.

   

Process

Regulatory return preparation, exception review, AML/compliance reporting, policy monitoring

Converts account, transaction, KYC, fraud, and service data into supervisory and management outputs.

   

Technology

Compliance reporting platforms, data warehouses, MIS/reporting tools, document repositories

Draws from core banking, KYC, fraud, and reconciliation systems to produce supervisory information.

   

Third Party

Regulatory portals, external data/reporting utilities, and audit support providers

External interfaces support submission, validation, and independent review of compliance outputs.

1.18

Business Continuity and Service Recovery

People

Business continuity coordinators, IT disaster recovery teams, crisis management teams, and business owners

Coordinate continuity responses, workarounds, recovery priorities, and stakeholder communications for CBS-1.

   

Process

Incident response, alternate processing, manual workaround, service restoration, recovery communication, lessons learned

Provides the cross-cutting recovery layer that protects all prior Sub-CBS when disruptions affect people, processes, technology, or third parties.

   

Technology

DR environment, backup infrastructure, alternate connectivity, resilience monitoring, and incident tools

Supports the restoration of account servicing, transaction processing, channels, and reporting within an acceptable disruption tolerance.

   

Third Party

Alternate site providers, telecom carriers, cloud/hosting partners, critical service vendors

The resilience of third parties directly affects the bank’s ability to restore customer access and maintain service within tolerance.

Regulatory Requirements and Examples Relevant to the Mapping

BSP Circular No. 1203 expects BSFIs to identify critical operations, set tolerance for disruption, determine severe but plausible scenarios, and then map interconnections and interdependencies end-to-end.

The Circular expressly says banks should identify the resources that keep critical operations running, including people, processes, technology, information, facilities, and resources under third-party service arrangements.

In the self-assessment annex, BSP also asks whether the BSFI has identified the personnel responsible for mapping, mapped the interconnections and interdependencies, identified the key sources and resources supporting the mapping, considered third-party involvement, identified vulnerabilities from the mapping exercise, and kept the mapping up to date.

For a Philippine bank such as PBCom, the regulator’s examples are directly relevant to Deposit and Account Services. BSP strongly encourages severe but plausible scenarios such as the “Big One”, a severe typhoon, failure of a critical third-party service provider, disturbance in payment and settlement systems, and a simultaneous or coordinated cyberattack/ransomware incident affecting multiple banks.

-BSP also expects banks to assess the substitutability of critical third parties, including the option to revert to in-house arrangements, and to integrate BCM, incident response, recovery planning, and testing with critical operations and disruption tolerance.

In practical terms, for CBS-1, that means mapping must show not only normal operations but also fallback paths for account opening, transaction posting, ATM/card access, digital login, reconciliations, and customer servicing when a major dependency fails.

 

Banner [Summing] [OR] [E3] Map Dependency

The dependency map for CBS-1 Deposit and Account Services should be read as a resilience tool, not just a process inventory.

Its value lies in revealing where PBCom’s customer-facing service depends on a small number of people, a single process checkpoint, a fragile technology component, or a concentrated third-party relationship.

That is exactly the purpose described by BCM Institute’s mapping approach and reinforced by BSP Circular No. 1203: to understand end-to-end delivery, identify vulnerabilities, and prioritise action before disruption turns into material customer harm. (BCM Institute Blog)

For PBCom, the most important next step after preparing this map would be to validate it with business owners, operations, compliance, IT, digital banking, card operations, fraud, and continuity teams; identify single points of failure; and align the findings to disruption tolerance, scenario testing, third-party resilience expectations, and recovery playbooks.

In BSP terms, the map should remain dynamic, regularly updated, and linked to vulnerability assessment, change management, BCM, and testing so that Deposit and Account Services can continue, degrade safely, or recover quickly under severe but plausible events.

If you want this converted next into a Map Processes and Resources table or an Impact Tolerance table for the same CBS, I’ll keep the same Sub-CBS structure.

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[OR] [PBCOM] [E3] [CBS] [1] [DP] Deposit and Account Services [OR] [PBCOM] [E3] [CBS] [1] [MD] Map Dependency [OR] [PBCOM] [E3] [CBS] [1] [MPR] Map Processes and Resources [OR] [PBCOM] [E3] [CBS] [1] [ITo] Establish Impact Tolerances [OR] [PBCOM] [E3] [CBS] [1] [SuPS] Identify Severe but Plausible Scenarios [OR] [PBCOM] [E3] [CBS] [1] [ST] Perform Scenario Testing

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