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From Risk to Resilience: A Strategic Operational Resilience Framework for Philippine Trust Company
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[OR] [PTC] [E3] [CBS] [1] [MD] Map Dependency

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 For the Philippine Trust Company, mapping dependencies for CBS-1 Deposit and Account Services is a core operational resilience activity because the service depends on an interconnected chain of people, processes, technology, public infrastructure, and third parties that must continue to work together during disruption. 

BCM Institute’s guidance explains that dependency mapping is intended to identify the connections among people, processes, information, technology, facilities, and service providers required to deliver each critical business service, enabling early identification of weaknesses and vulnerabilities. 

BSP Circular No. 1203 takes the same direction by requiring BSFIs to identify critical operations, map interconnections and interdependencies, assess vulnerabilities, and ensure that third-party and public infrastructure dependencies are understood and managed.

Philtrust’s public materials show that its domestic services include checking accounts, savings accounts, time deposits, transfers, collections, and related account services, making deposit and account servicing an appropriate, critical business service to map in detail.

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Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

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[OR] [PTC] [PH] [E3] [CBS] [1] [MD] Deposit and Account ServicesFor the Philippine Trust Company, mapping dependencies for CBS-1 Deposit and Account Services is a core operational resilience activity because the service depends on an interconnected chain of people, processes, technology, public infrastructure, and third parties that must continue to work together during disruption. 

BCM Institute’s guidance explains that dependency mapping is intended to identify the connections among people, processes, information, technology, facilities, and service providers required to deliver each critical business service, enabling early identification of weaknesses and vulnerabilities. 

BSP Circular No. 1203 takes the same direction by requiring BSFIs to identify critical operations, map interconnections and interdependencies, assess vulnerabilities, and ensure that third-party and public infrastructure dependencies are understood and managed.

Philtrust’s public materials show that its domestic services include checking accounts, savings accounts, time deposits, transfers, collections, and related account services, making deposit and account servicing an appropriate, critical business service to map in detail.
The dependency map below is structured to support an operational resilience assessment of Philtrust’s deposit and account service chain.

It aligns each Sub-CBS with the four requested dependency lenses: People, Process, Technology, and Third Party.

The examples are tailored to a Philippine bank context and reflect BSP expectations that banks identify key roles, supporting resources, substitute arrangements, incident and continuity measures, and vulnerabilities that may affect the delivery of critical operations.

Where Philtrust-specific internal systems or vendors are not publicly disclosed, the table uses reasonable banking-industry dependency assumptions that the bank should validate during workshops and mapping reviews. 

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 staff, relationship managers, operations support

Frontline staff initiate the deposit-service lifecycle by receiving applications and customer data, which feeds KYC, approval, and account setup.

   

Process

Customer onboarding workflow, form completion, document capture, product suitability checks

Starts the end-to-end deposit account journey and triggers downstream KYC/CDD, approval, CIF creation, and initial funding steps.

   

Technology

Branch onboarding platform, document scanning, CRM/CIF capture, queue management

Captures applicant data and supporting records for use by compliance, operations, and core banking account-opening processes.

   

Third Party

ID validation utilities, courier/printing partners for forms/cards, telecom/internet providers

External services support document transmission, identity reference checks, and connectivity needed for branch or digital onboarding.

1.2

Customer Identification and Verification (KYC/CDD)

People

Compliance officers, branch officers, AML analysts, and account-opening reviewers

Review the customer's identity, beneficial ownership, and risk profile before the account is activated.

   

Process

KYC, CDD, sanctions screening, AML risk rating, customer acceptance standards

Determines whether onboarding can proceed and links directly to fraud controls, compliance monitoring, and regulatory reporting.

   

Technology

AML screening engine, watchlist screening, document management, customer risk-rating tools

Interfaces with onboarding and core customer records to prevent non-compliant or suspicious accounts from being opened.

   

Third Party

Sanctions/watchlist data providers, public registry sources, telecom/network providers

Supplies external reference data and connectivity needed to validate customer identity and screening results.

1.3

Account Approval and Opening

People

Approvers, branch managers, operations control staff, and account setup personnel

Authorised staff approve the customer relationship and confirm that onboarding and KYC conditions are satisfied.

   

Process

Approval matrix, maker-checker controls, account-number generation, and account activation

Converts a verified application into a live deposit account and enables initial funding, servicing, and transaction processing.

   

Technology

Core banking platform, CIF master, account origination module, workflow engine

Generates the official account record used by tellers, ATM, digital banking, statements, and reconciliation processes.

   

Third Party

Signature card printers, cheque/passbook vendors, network/connectivity providers

Supports issuance of physical account instruments and operational connectivity after account creation.

1.4

Initial Funding and Deposit Booking

People

Tellers, branch cash custodians, operations staff, treasury/settlement support

Handle cash, cheque, transfer, or remittance-based initial funding and ensure correct booking into the account.

   

Process

Cash acceptance, cheque clearing intake, transfer posting, deposit booking and balancing

Establishes the funded status of the account and links account opening to ledger posting and available balance creation.

   

Technology

Teller system, core banking, cash transaction module, clearing interface

Post the first deposit to the ledger and update balances used by withdrawals, ATM, and digital banking channels.

   

Third Party

Clearing houses, cash logistics support, and payment network participants

External settlement or clearing dependencies affect how quickly funds become collected and usable.

1.5

Product Terms Setup and Account Parameter Maintenance

People

Product management, deposit operations, branch operations, IT support

Staff define or maintain account parameters such as minimum balance, dormancy rules, interest basis, and fee settings.

   

Process

Product configuration, parameter maintenance, change control, and authorisation workflow

Ensures the account behaves correctly with respect to pricing, eligibility, customer service, and compliance conditions.

   

Technology

Core banking parameter tables, product engine, and change management tools

Parameter settings drive transaction validation, fee charging, interest accrual, dormancy treatment, and reporting.

   

Third Party

System vendors, managed service providers, testing/support partners

Vendor-supported system changes may be needed when product terms or regulatory rules are updated.

1.6

Deposit Transactions Processing

People

Tellers, branch operations, operations back office, supervisors

Execute and supervise cash and non-cash deposit transactions and resolve posting exceptions.

   

Process

Deposit acceptance, validation, posting, end-of-day balancing, exception handling

Maintains accurate account balances and feeds downstream reporting, reconciliation, and customer visibility across channels.

   

Technology

Teller platform, core banking, branch network, transaction switch

Real-time or near-real-time posting connects branch activity to the central ledger and customer channels.

   

Third Party

Telecom/network providers, clearing participants, device maintenance providers

Service availability of communications and transaction devices affects transaction throughput and posting timeliness.

1.7

Withdrawal and Funds Access Processing

People

Tellers, cash custodians, branch managers, fraud/risk monitoring staff

Staff validate customer authority, check balances or holds, and release funds within policy limits.

   

Process

OTC withdrawal, signature verification, withdrawal limit checks, hold validation, approval controls

Connects directly to balance management, fraud checks, ATM/card controls, and customer access obligations.

   

Technology

Teller system, core banking, signature verification records, ATM/card systems

Confirms available balance and restrictions before funds are dispensed or released to the customer.

   

Third Party

ATM network operators, cash-in-transit, telecom/internet providers

External channel and cash dependencies influence the bank’s ability to provide uninterrupted access to deposits.

1.8

Account Servicing and Customer Maintenance

People

Customer service staff, branch operations, contact centre, operations support

Handle account updates, including address changes, reactivation requests, record amendments, and service requests.

   

Process

Customer maintenance workflow, record update controls, request fulfilment, maker-checker approval

Keeps account records accurate and supports continuity of statements, notifications, fraud monitoring, and regulatory compliance.

   

Technology

CRM/CIF system, core banking maintenance screens, document repository

Updated customer data propagates across servicing, digital access, alerts, and compliance monitoring systems.

   

Third Party

SMS/email service providers, call centre support, document archiving partners

Customer updates often rely on third-party communication and storage services for fulfilment and evidence retention.

1.9

Interest, Fees, and Charges Processing

People

Product operations, finance, deposit operations, and branch support

Staff oversee correct accruals, fee collection, reversals, and customer enquiries on account pricing outcomes.

   

Process

Interest accrual, fee computation, penalty charging, waiver/adjustment approvals

Directly impacts customer balances, disclosures, complaints, and the accuracy of financial reporting.

   

Technology

Core banking interest engine, fee tables, batch processing, and general ledger interfaces

Automates periodic account calculations and posts results to customer accounts and bank finance records.

   

Third Party

System vendors, managed infrastructure providers

Reliable batch execution and parameter integrity may depend on external platform support.

1.10

Statement, Passbook, and Balance Reporting

People

Branch staff, operations reporting staff, customer service staff

Produce or support the delivery of passbooks, statements, balance confirmations, and customer transaction history.

   

Process

Statement generation, passbook updating, balance inquiry, archival retrieval, report distribution

Provides customers with evidence of account activity and supports dispute handling, auditing, and compliance needs.

   

Technology

Statement engine, passbook printers, report repository, core banking inquiry tools

Pulls transaction and balance data from the ledger and makes it available to branches, online channels, and service teams.

   

Third Party

Print/mail providers, email/SMS providers, telecom/network providers

Delivery of paper or electronic statements depends on external fulfilment and communications channels.

1.11

Digital Account Access and Channel Integration

People

Digital banking team, IT operations, cyber security staff, and customer support

Manage customer access, platform availability, integration incidents, and channel-related service issues.

   

Process

Login and authentication, online inquiry, transfer initiation, digital service support, and incident escalation

Extends deposit services beyond branches and connects CBS-1 to customer-facing digital channels and related controls.

   

Technology

Internet/mobile banking platforms, middleware, API/integration layers, IAM/MFA tools

Provides customers with self-service access to balances, transactions, and accounts using the same core account records.

   

Third Party

Internet service providers, OTP/SMS vendors, cybersecurity solutions providers, app support vendors

Availability and security of digital services depend on external connectivity, messaging, and cyber-control suppliers.

1.12

ATM and Card-Based Access Management

People

Card operations staff, ATM support teams, fraud monitoring analysts, and branch service staff

Support ATM card issuance, PIN handling, card replacement, dispute support, and access restoration.

   

Process

Card issuance, PIN generation, activation, blocking/hotlisting, ATM withdrawal and balance inquiry processing

Connects deposit accounts to ATM-based access, widening service reach and dependence on switching/network availability.

   

Technology

Card management system, ATM switch, ATM terminals, core banking integration

Enables real-time authentication and balance validation for ATM withdrawals and inquiries.

   

Third Party

BancNet or other network participants, card vendors, ATM hardware maintainers, cash-in-transit providers

Critical external dependencies support network transactions, card production, ATM uptime, and cash replenishment.

1.13

Account Reconciliation and Exception Handling

People

Operations control staff, branch accounting staff, finance/reconciliation analysts

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

   

Process

Daily reconciliation, suspense management, break investigation, correction and adjustment workflow

Protects ledger integrity and ensures that branch, channel, and settlement records remain aligned with customer balances.

   

Technology

Reconciliation tools, core banking extracts, general ledger interface, and exception tracking logs

Aggregates transaction data from multiple channels and systems to identify and resolve breaks.

   

Third Party

Network providers, settlement counterparties, managed reconciliation tools

The timeliness of third-party data and the completeness of files affect the speed of exception resolution.

1.14

Dormancy, Holds, Restrictions, and Account Control Administration

People

Branch managers, compliance staff, legal staff, and deposit operations

Authorise or administer holds, garnishments, freezes, dormancy treatment, and account control actions.

   

Process

Dormancy monitoring, freeze/unfreeze controls, legal hold processing, restriction administration

Controls customer access and ensures that withdrawals, transfers, and servicing follow legal, risk, and policy requirements.

   

Technology

Core banking restriction codes, account control flags, case/workflow tools

Restriction settings interact directly with teller, ATM, and digital access processes to prevent unauthorised use.

   

Third Party

Legal notice originators, government agencies, external mail/notice service providers

External instructions or notifications may trigger account controls and customer communications.

1.15

Fraud Monitoring and Transaction Surveillance for Deposit Accounts

People

Fraud analysts, AML team, branch operations, and information security staff

Monitor unusual account behaviour, internal fraud indicators, mule activity, or transaction anomalies.

   

Process

Fraud detection, alert triage, case investigation, escalation, account blocking, suspicious activity referral

Operates across withdrawals, digital access, ATM transactions, and account maintenance to reduce harm and protect customers.

   

Technology

Fraud monitoring systems, AML tools, transaction analytics, alert/case platforms

Pulls data from core banking and delivery channels to identify patterns that may threaten the CBS.

   

Third Party

Fraud intelligence providers, cyber monitoring vendors, telecom/SMS providers

External feeds and communications support alert enrichment, customer contact, and rapid response.

1.16

Complaints, Disputes, and Service Recovery

People

Branch staff, complaints handling unit, customer care teams, operations investigators

Receive and resolve complaints on failed transactions, statement issues, unauthorised use, or service interruptions.

   

Process

Complaint logging, dispute investigation, root-cause analysis, correction, and customer communication

Feeds back into operational resilience by identifying control weaknesses and customer harm from service disruption.

   

Technology

CRM/ticketing system, call centre tools, case management, transaction history inquiry systems

Enables cross-functional review of incidents and ties customer impact to operational breaks and remediation.

   

Third Party

Ombudsman/regulatory channels, communications providers, ATM/network participants

Some disputes require coordination with external networks or communication providers for evidence and resolution.

1.17

Regulatory Reporting and Compliance Monitoring

People

Compliance officers, finance staff, operations reporting teams, and internal audit liaison

Prepare and review required reporting, compliance monitoring, and issue escalation related to deposit operations.

   

Process

Regulatory returns, exception reporting, compliance attestations, and audit issue tracking

Connects CBS-1 operations to BSP, AML, consumer protection, and deposit insurance obligations.

   

Technology

Regulatory reporting tools, data warehouse, MIS reporting, compliance dashboards

Consolidates information from onboarding, transactions, fraud, and servicing for external and internal reporting.

   

Third Party

Regulators, reporting gateways, legal/compliance advisers, PDIC-related interfaces

External regulatory bodies and reporting channels shape reporting timetables and issue management.

1.18

Incident Response, Business Continuity, and Recovery

People

Incident management team, business continuity coordinators, IT DR teams, senior management, branch leadership

Lead disruption response, decision-making, escalation, communication, and recovery actions affecting deposit services.

   

Process

Incident response, crisis management, BCP invocation, manual workarounds, recovery and restoration

Coordinates end-to-end resilience when any of the preceding Sub-CBS activities are disrupted beyond normal tolerance.

   

Technology

DR site, backup systems, alternative connectivity, monitoring tools, emergency communication platforms

Supports restoration of core deposit operations, alternative service delivery, and post-incident recovery validation.

   

Third Party

Alternate site providers, telecom and power utilities, critical vendors, security/logistics partners

External resilience arrangements are essential for maintaining or restoring service during severe but plausible scenarios.

Regulatory requirements and Philippine banking examples

BSP Circular No. 1203 requires a BSFI’s board to oversee and approve an operational resilience framework, while senior management must implement it and ensure sufficient resources and capabilities are in place.

For a bank such as Philtrust, this means deposit and account services cannot be treated as branch-only activities; the service must be governed as a cross-functional critical operation that includes operations, compliance, IT, fraud, customer service, and third-party oversight.

The Circular also states that identified critical operations should drive the subsequent steps of setting disruption tolerances and mapping interconnections and interdependencies.

In practice, once Philtrust identifies deposit and account services as a critical operation, it should map the people, systems, channels, and external providers that support each sub-process above, then use that map to identify weak points such as single approver dependency, sole telecom link, sole ATM switch dependency, or over-reliance on one KYC or messaging provider.

BSP further expects third-party arrangements affecting critical operations to include provisions to maintain those operations during disruptions, or an exit strategy and substitute arrangements must exist.

For example, if digital deposit access depends on an OTP provider, an ATM network, a statement printer, or a managed infrastructure provider, the bank should define fallback arrangements, substitute vendors, or in-house alternatives where feasible.

The self-assessment questions attached to the Circular also ask whether the bank has identified the personnel responsible for mapping, the key sources and resources used, and the plans for the unavailability of key roles.

Finally, BSP requires banks to assess dependencies on public infrastructure such as telecommunications and energy, and to perform periodic business continuity exercises using severe but plausible scenarios.

For deposit and account services, examples include a branch network outage, ransomware affecting account access, an ATM switch failure, a prolonged telecom outage, a critical third-party service failure, or a simultaneous disruption affecting multiple customer-access channels.

These examples show why the dependency map must be kept current and tied to scenario testing, recovery plans, and vulnerability remediation.

 

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

The dependency mapping for CBS-1 Deposit and Account Services shows that Philippine Trust Company’s deposit service is not a single operational process but an ecosystem of linked activities spanning onboarding, KYC, account opening, posting, access channels, controls, reporting, and recovery.

Consistent with BCM Institute’s mapping guidance and BSP Circular No. 1203, the value of the map lies in making those interconnections visible, enabling the bank to identify vulnerabilities, test disruption scenarios, define substitute arrangements, and strengthen its ability to continue delivering critical services during operational stress.

As a chapter output, this table should be treated as the working dependency baseline for the next operational resilience steps: mapping processes and resources, setting impact tolerances, defining severe but plausible scenarios, and planning scenario tests.

Philtrust should validate the draft against its actual branch model, core banking architecture, third-party inventory, ATM and digital channel arrangements, and governance structure, so that the final map is evidence-based, regulator-ready, and actionable for improving resilience.

 

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