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Understanding Third-Party Risk Management (TPRM) in Operational Resilience
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[OR] [Pillar] [E4] [C8] Case Study – Implementing TPRM for Operational Resilience

This chapter presents a practical case study illustrating how financial institutions implement Third-Party Risk Management (TPRM) as part of their Operational Resilience (OR) programmes.

 

Using two representative institutions—a Philippine bank aligned with BSP Circular No. 1203 (2024) and a Malaysian bank aligned with BNM Operational Resilience expectations—this case study demonstrates how TPRM frameworks, governance, tools, and scenario testing are applied in real-world contexts.

The case study integrates concepts covered throughout this eBook, including:

  • Critical Business Services (CBS)
  • Third-party risk identification and classification
  • TPRM lifecycle and governance
  • Scenario testing and impact tolerance
  • Regulatory compliance and reporting

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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eBook 4: Chapter 7

TPRM Regulatory Compliance Checklist

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Introduction

This chapter presents a practical case study illustrating how financial institutions implement Third-Party Risk Management (TPRM) as part of their Operational Resilience (OR) programmes. 

Using two representative institutions—a Philippine bank aligned with BSP Circular No. 1203 (2024) and a Malaysian bank aligned with BNM Operational Resilience expectations—this case study demonstrates how TPRM frameworks, governance, tools, and scenario testing are applied in real-world contexts.

The case study integrates concepts covered throughout this eBook, including:

  • Critical Business Services (CBS) 

  • Third-party risk identification and classification 

  • TPRM lifecycle and governance 

  • Scenario testing and impact tolerance 

Regulatory compliance and reporting 

 

Purpose of This Chapter

By the end of this chapter, readers will:

  • Understand how TPRM is implemented in practice
  • See how frameworks translate into operational execution
  • Learn from real-world challenges and solutions
  • Apply lessons to their own organisations

 

Section 1: Case Study Overview

Profile of Institutions

 

Attribute

Philippine Bank

Malaysia Bank

Regulatory Framework

BSP Circular No. 1203

BNM Operational Resilience

Business Focus

Retail and commercial banking

Universal banking

Key CBS

CBS-1 Deposit Services, CBS-2 Payments

CBS-1 Deposits, CBS-2 Digital Banking

Third-Party Dependency

High (IT, KYC, Payments)

High (Cloud, Fintech, Outsourcing)

 

Section 2: Identifying Critical Business Services (CBS)

Example CBS Mapping

 

CBS

Description

Key Third Parties

CBS-1 Deposit Services

Account management, transactions

Core banking vendor, KYC provider

CBS-2 Payments

Funds transfer, clearing

Payment gateway, telecom provider

CBS-3 Digital Banking

Mobile and online banking

Cloud provider, cybersecurity vendor

 

👉 Implementation Insight:
Both banks began by mapping CBS and identifying third-party dependencies, as required by BSP and BNM.

 

Section 3: TPRM Framework Implementation

Step 1: Vendor Inventory and Classification

 

Vendor

Service

CBS

Criticality

Risk Level

Core Banking Vendor

Core system

CBS-1

Critical

High

Cloud Provider

Infrastructure

CBS-3

Critical

High

KYC Vendor

Customer verification

CBS-1

High

Medium

 

Outcome:

  • Philippine Bank identified 120 vendors, with 25 classified as critical
  • Malaysia Bank identified 150 vendors, with 30 critical

 

Step 2: Risk Assessment and Scoring

 

Vendor

Inherent Risk

Control Effectiveness

Residual Risk

Cloud Provider

5.0

60%

2.0

Payment Gateway

4.5

50%

2.25

Insight:

  • High reliance on cloud services increased cyber and concentration risk
  • Both banks enhanced monitoring for high-risk vendors

 

Step 3: Governance and Operating Model

 

Element

Philippine Bank

Malaysia Bank

3 Lines of Defence

Implemented

Implemented

TPRM Function

Centralised

Hybrid

Board Oversight

Quarterly reporting

Integrated into OR governance

 

Section 4: Scenario Testing for Third-Party Failures

Scenario 1: Cloud Provider Outage

 

Item

Philippine Bank

Malaysia Bank

CBS Impacted

CBS-1, CBS-3

CBS-2, CBS-3

Impact

Digital banking outage

Payment disruption

MTD

4 hours

2 hours

Outcome

Within tolerance

Exceeded tolerance

Lessons Learned
  • Philippine Bank improved its failover capability
  • Malaysia Bank implemented a multi-cloud strategy

 

Scenario 2: Payment Gateway Failure

 

Item

Philippine Bank

Malaysia Bank

CBS Impacted

CBS-2

CBS-2

Impact

Transaction delays

Transaction failure

Response

Queue transactions

Switch to backup vendor

Outcome

Partial success

Successful recovery

 

Scenario 3: Vendor Cyberattack

Item

Philippine Bank

Malaysia Bank

CBS Impacted

CBS-1

CBS-3

Impact

Data exposure risk

Service disruption

Response

Incident response activation

Isolate affected systems

Outcome

Managed

Improved controls required

 

Section 5: Compliance Alignment

Regulatory Compliance Assessment

 

Area

Philippine Bank (BSP)

Malaysia Bank (BNM)

CBS Mapping

Fully compliant

Fully compliant

Third-Party Risk Assessment

Fully compliant

Fully compliant

Scenario Testing

Partial

Fully compliant

Monitoring

Established

Mature

 

Section 6: Challenges and Solutions

Key Challenges

 

Challenge

Impact

Solution

Lack of vendor visibility

Incomplete risk view

Implement vendor inventory

Over-reliance on a single vendor

Concentration risk

Introduce redundancy

Limited scenario testing

Weak resilience validation

Develop scenario library

Data from vendors is not timely

Monitoring gaps

Automate reporting

 

Section 7: Key Success Factors

 

1. Strong Governance

Clear accountability across business, risk, and audit.

2. CBS-Centric Approach

Focus on services rather than individual vendors.

3. Risk-Based Prioritisation

Focus on high-risk and critical vendors.

4. Continuous Monitoring

Use dashboards and KPIs.

5. Scenario Testing

Validate resilience under real conditions.

 

Section 8: Implementation Roadmap (Practical Guide)

Recommended Steps for Participants

 

Step

Action

1

Identify CBS

2

Map third-party dependencies

3

Perform risk assessment

4

Establish governance

5

Implement monitoring tools

6

Conduct scenario testing

7

Align with regulatory requirements

 

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  • TPRM is critical to Operational Resilience
  • CBS mapping is the foundation of effective implementation
  • Scenario testing reveals real vulnerabilities
  • Governance ensures accountability and oversight
  • Regulatory alignment strengthens resilience and compliance

 

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This case study demonstrates that implementing Third-Party Risk Management is a journey that requires structured frameworks, strong governance, and continuous improvement.

Both the Philippine and Malaysian banks illustrate how TPRM can be effectively embedded into Operational Resilience programmes to ensure the continuity of critical business services.

By adopting a CBS-driven approach, integrating scenario testing, and aligning with regulatory expectations, including BSP Circular No. 1203 and BNM guidelines, organisations can transform third-party dependencies into controlled, resilient partnerships.

Ultimately, successful TPRM implementation enables organisations not only to comply with regulations but also to build a robust, adaptive, and future-ready operational resilience capability.

 

[Pillar] [3_4] [Banner] [C4] Third-Party Risk Management

C1 C2 C3 C4
[OR] [Pillar] [E4] [C1] Introduction to TPRM [OR] [Pillar] [E4] [C2] Types of Third-Party Risks [OR] [Pillar] [E4] [C3] Framework and Lifecycle [OR] [Pillar] [E4] [C4] Governance and Operating Model
C5 C6 C7 C8
[OR] [Pillar] [E4] [C5] Tools, Templates and Scoring Models [OR] [Pillar] [E4] [C6] Scenario Testing for Third-Party Failures [OR] [Pillar] [E4] [C7] Regulatory Compliance Checklist [OR] [Pillar] [E4] [C8] Case Study_ Implementation in Banking

 

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