=Paper= {{Paper |id=Vol-1517/JOWO-15_WoMO_paper_3 |storemode=property |title=OntoBacen: A Modular Ontology for Risk Management in the Brazilian Financial System |pdfUrl=https://ceur-ws.org/Vol-1517/JOWO-15_WoMO_paper_3.pdf |volume=Vol-1517 |dblpUrl=https://dblp.org/rec/conf/ijcai/PolizelCS15 }} ==OntoBacen: A Modular Ontology for Risk Management in the Brazilian Financial System== https://ceur-ws.org/Vol-1517/JOWO-15_WoMO_paper_3.pdf
                     OntoBacen: A Modular Ontology for Risk Management
                              in the Brazilian Financial System

               Filipe Polizel                                 Sara Casare                        Jaime Sichman
    Instituto de Matemática e Estatı́stica                IBM do Brasil                         Escola Politécnica
         Universidade de São Paulo                     sjcasare@uol.com.br                  Universidade de São Paulo
             fpolizel@ime.usp.br                                                             jaime.sichman@poli.usp.br


                          Abstract                                          Financial Industry Risk Management
     This paper presents a first semantic formalization of           The main good practices for the governance of the global fi-
     the Brazilian financial system risk management poli-            nancial system were established and formalized by the Basel
     cies, called OntoBacen, that is based on a modularized          Committee on Banking Supervision (BCBS), forming part
     approach. We show some partial results generated by             of the Bank for International Settlements (BIS), that in post-
     a knowledge-based system that uses an ontology con-             crisis periods identified the need for a robust data manage-
     structed to address some domain questions.                      ment framework. This must ensure that banks have the ca-
                                                                     pacity to aggregate risk exposure data in an integrated man-
Episodes like global crisis undermine people’s confidence            ner, reaching all the corporation levels, in addition to stan-
in the financial system, but also provide lessons for the fu-        dardized risk reporting practices (BIS 2013a), confering the
ture. The 2007-2008 meltdown resulted in a significative             degrees of assertiveness and timeliness required by institu-
advancement of governance policies followed by financial             tional leaders for decision-making in times of stress.
institutions worldwide, with some of them treating classic              Once established the core principles for banking supervi-
data management problems, as integrity and completeness.             sion (BIS 1997; BIS 2012), central banks around the globe
To enable the adoption of an integrated and robust global fi-        have taken them as basis for the establishment of their own
nancial system, IT companies and financial institutions are          regulatory norms. Moreover, they also considered the sin-
joining efforts for the creation and adoption of a technolog-        gularities of their domestic financial systems, what partially
ical framework to better meet the industry needs.                    mitigated the level of heterogeneity of the global financial
   The main goal of this work is to explore alternative ap-          system risk management domain. However, this was not suf-
proaches for the conceptualization and definition of busi-           ficient to achieve the goal of representing these domain con-
ness rules present in governance policies of the Brazilian           cepts and their relationships in an integrated manner world-
financial system, more specifically those related to risk man-       wide, which demands the use of highly integrable and log-
agement. To this end, it proposes an ontology, called Onto-          ically grounded tools, such as the use of formal ontologies
Bacen, that expresses the concepts (and their relationships)         (Guarino 1995) in the Semantic Web (Berners-Lee, Handler,
of this domain, and by using inference algorithms, can ver-          and Lassila 2001).
ify the compliance of hypothetical financial institutions with
                                                                        The policies and guidelines to be followed by the Brazil-
those policies.
                                                                     ian financial institutions are created and maintained by the
   For such a wide and complex domain, modularity must
                                                                     local monetary authorities, but mainly by the executive au-
play a central role in the design of the proposed solution,
                                                                     thority of the national financial system, the Brazil Central
to ensure that it results in an coherent, understandable and
                                                                     Bank, also known as BACEN. In order to align their gover-
scalable knowledge-based system.
                                                                     nance policies with the Basel principles, the Brazilian mon-
   In the following section, the risk management setting of
                                                                     etary authorities created a series of norms, known as pru-
the Brazilian financial system is briefly introduced. We then
                                                                     dential regulation (BACEN 2014), to be followed by local
present the main initiatives involving ontologies for the fi-
                                                                     banks and financial institutions. The main goal of the pru-
nancial industry, followed by a description of OntoBacen
                                                                     dential regulation is to consolidate a national system for risk
by means of its properties and requirements. In the sequence,
                                                                     management and capital adequacy.
we show the modularization approach adopted by the pro-
                                                                        These regulations are arranged to take into account the
posed solution, followed by a section that details how On-
                                                                     main types of risk, described as follows:
toBacen has been developed and how it’s meant to be used.
Some test cases illustrate the use of the proposed ontol-            Credit Risk Associated with the risk of default, the failure
ogy, followed by current conclusions and future develop-               to comply with obligations and responsibilities.
ment steps.
                                                                     Market Risk Related to the volatility of rates or prices over
                                                                      the time, such as currency exchange and interest rates, or
                                                                      prices of securities and commodities.
Operational Risk Associated with the probability of loss                 These initiatives are being conducted with the support of
   resulting from internal processes failures or deficiencies,        the Governance, Risk and Compliance Technology Centre3
   including legal risks, such as damages to third parties aris-      (GRCTC), also responsible for the development of the Fi-
   ing from its activities, or violation of rules established in      nancial Industry Regulatory Ontology (FIRO) and the Finan-
   their jurisdiction.                                                cial Governance, Risk and Compliance Ontology (FIGO).
   This business division of the domain suggests that mod-
ularity should be taken into account (and exploited to the                                OntoBacen Proposal
fullest) when dealing with risk management.                           The final and main goal of this work is to create an ontol-
                                                                      ogy to represent the Brazilian financial system, by means
           Ontologies for Financial Industry                          of its risk management concepts, and to be implemented in
In recent years, with the greater control over the financial          the Web Ontology Language (OWL). In this sense, it is re-
systems by regulatory agencies, the need for information              lated to some of the ontologies mentioned in the previous
systems interoperability and data integration has increased,          section, while considering BACEN’s governance policies, as
which strengthened initiatives related to finance on the Se-          published in its norms.
mantic Web; these initiatives, allied with the ontologies’ se-           A Brazilian financial jargon says that BACEN’s regula-
mantic formalism, have gained their place and importance in           tions are the “tropicalization of Basel”. To exemplify this
this specific industry.                                               statement, when comparing BACEN and Basel standardized
    As an example, the Suggested Upper Merged Ontology                approaches to evaluate market risks, one can conclude that
(Niles and Pease 2001), also known as SUMO, has included              the BACEN approach has an additional component of risk
its own finance domain ontology years ago, dealing with               for fixed interest rates denominated in the local currency
concepts related primarily to financial services, typical of          (real), making it a conservative adaptation of the Basel ap-
commercial banks, such as bank accounts, payments, loans,             proach (BIS 2013b).
etc. A more recent work (in progress at the time of writ-                The specification of OntoBacen, by means of its require-
ing), is the Financial Report Ontology1 (FRO), which pro-             ments, is given by a set of competence questions (Grüninger
vides formal and structured meta-information about finan-             and Fox 1995), as shown in the following:
cial reports, such as balance-sheets; it is primarily based
                                                                      CQ1: What is the capital structure, by means of its compo-
on a well-known XML schema for this application domain,
                                                                       nents, of a financial institution that belongs to the Brazil-
XBRL (Engel et al. 2013), that stands for eXtensible Busi-
                                                                       ian financial system?
ness Reporting Language.
    Other relevant initiative is the Financial Industry Busi-         CQ2: What are the maximum and minimum constraints for
ness Ontology2 (FIBO), a series of standards being devel-              the capital components of a Brazilian financial institution?
oped by the Enterprise Data Management Council (EDMC)                 CQ3: What are the cash amounts that represent each capital
and published following the technical governance process of            component of a Brazilian financial institution?
the Object Management Group (OMG). FIBO currently pro-
vides a framework of conceptual definitions concerning the            CQ4: Do the capital components of a Brazilian financial
wide spectrum of financial applications, currently available           institution respect its constraints?
for use in two modules.                                                  The definition of capital component used in this paper is
    The first module, FIBO foundations, defines high-level            that of a grouping of assets or liabilities, possibly weighted
financial concepts such as currency or contracts, and even            by some factor and represented by an amount of money.
non-financial concepts such as autonomous agent or coun-                 Aditionally, for the development of the proposed ontol-
try, that are need for the definition of more specific finan-         ogy, a methodology partially based on the GRCTC method-
cial concepts. The second module, FIBO Business Entities,             ology (adopted by FIRO and FIGO) will be used, as shown
defines concepts such as legal persons and corporations, en-          in the Construction and Usage section.
tities that could incur legal obligations such as establishing
business contracts with other entities.                                              OntoBacen Modularization
    There are also ontological initiatives concerning financial
regulations, where lies the scope of this work. Abi-Lahoud            The BACEN’s prudential regulation is the starting point for
et al. (2013) developed an ontology concerning the com-               the definition of OntoBacen. It was analyzed in a top-down
pliance with American anti-money-laundering regulations;              approach, beginning with the most high-level view, repre-
later, Abi-Lahoud, OBrien, and Butler (2013) presented an             sented by the notions related to the methodology for cal-
experimental discussion about the adopted approach, an it-            culation of the Reference Capital, later reaching the lower-
erative process based on subject-matter expertise and on the          level related concepts. In this sense, by the interpretation
use of structured natural language, more precisely based              of a series of BACEN documents, the lower level concepts
on SBVR (OMG 2008), that stands for Semantics of Busi-                were identified, introducing definitions related to several ap-
ness Vocabulary and Business Rules, a structured vocabu-              proaches for the measurement of different types of risk.
lary founded in formal logic.                                             After this domain analysis, some core modules were iden-
                                                                      tified for the development process, as shown in Figure 1.
   1
       See: http://xbrl.squarespace.com/financial-report-ontology/.
   2                                                                     3
       See: http://www.omgwiki.org/OMG-FDTF/doku.php.                        See: http://www.grctc.com/platform-research/.
      FIBO Foundations                  FIBO Business Entities    was added to treat the risk related to interest rates of bank-
                                                                  ing book assets, i.e. those acquired and meant to be held until
                                                                  their maturity, because the risk exposure calculation method
                             Foundations
                                                                  for these cases is different from the standard market risk for
                                                                  interest rates approach.
             Capital                             RWA                 An additional reason to adopt such modularization is that
            Tier 1 Core                       Market
                                                RWA  Risk         these subdomains are commonly subject of distinct business
                                                                  areas in financial institutions (specially the big ones). In this
    Tier 1 Complementary                      Credit Risk
                                                                  sense, the compliance area is more willing to treat issues
                Tier 2                      Operational Risk      addressed by the Capital ontologies, the market risk man-
        Permanent Limit                    Banking Book Risk      agement area to those of the Market Risk ontology, and so
                                                                  forth, in such a way that those areas could consult specific
  in development (blank)
  prototype ready (filled)                                        ontologies as semantics repositories or even use its inference
  dependency relation        Capital Requirements                 capabilities to address their own issues.
                                                                     Finally, an additional ontology, Capital Requirements,
                   Figure 1: OntoBacen modules                    deals with the capital adequacy questions mentioned in the
                                                                  proposal section. It is related to concepts defined in both
    Primarily, the FIBO Foundations and FIBO Business En-         Capital and RWA ontologies, and contains the definitions
tities ontologies were chosen to provide the highest level of     of business rules necessary for addressing CQ2.
semantics, such as the has part property, a whole-part rela-         Currently, the Foundations, Market Risk and Capital
tionship frequently used by OntoBacen, or even concepts           Requirements ontologies are ready to be used, as detailed
common in finance, such as currency.                              in the sequence. Consequently, the capital adequacy compe-
    Some additional concepts not present in FIBO were de-         tence questions address only market risk exposure.
fined to provide mid-level semantics, constituting the mod-
ule Foundations, that is supposed to be used by other mod-        Foundations Module
ules and ontologies of OntoBacen; it is composed by a set         This module is composed of four foundational ontologies,
of ontologies described later in this section.                    described as follows:
    The lower level ontologies are then separated in two major
disjoint groups: Capital and RWA. The first group addresses       Common Relations Ontology that defines a set of data and
the definition of capital, that is represented in an account-       object properties required by other ontologies, such as:
ing perspective by shareholder’s equity, savings and other          1. mathematical properties, to define product, minimum,
kinds of liabilities. The second group name is an acronym              maximum, and other derivation relationships;
for Risk Weighted Assets, that also in an accounting per-           2. time constraints properties, such as initial and ending
spective consists of the values of assets weighted by distinct         date (xsd:dateTime), minimum and maximum duration
types of risks according to the degree of risk exposure; these         (xsd:duration), needed for time intervals definition;
two groups encompass the concepts that must be defined for
addressing CQ1.                                                     3. the has reference date property, needed for the defini-
                                                                       tion of financial system governance contexts;
    To exemplify how RWA captures the notion of risk, one
could think, for instance, in a market risk perspective, if you     4. the has decimal value property, used to define factors;
have a given amount of resources applied in the stock mar-        BACEN Factors Ontology for the definition of constant or
ket and the same amount of resources applied in treasury            time dependant factors present in BACEN regulations.
bonds, it is expected that the weighting factor of the first        Time dependancy is defined by fixed xsd:dateTime inter-
group is higher than the second one’s weighting factor, and         vals or fixed xsd:duration intervals relative to a specific
consequently its RWA, because of the probability that the           date;
company which some stocks was acquired enter bankruptcy
is higher than that of the government defaulting.                 Financial Institutions Ontology encompassing concepts
    Each one of these groups were then divided in minor (and        that define the Brazilian financial system agents, such as:
also disjoint) modules. Capital group takes into account            1. The financial institutions classification, specializing the
BACEN major definitions to do these separation, being de-              concept for legal person from FIBO Business Entities.
composed in Tier 1 Core, Tier 1 Complementary and Tier                 Examples are commercial banks, investiment banks,
2 ontologies. The same group also encompasses a Perma-                 securities brokerages, etc.;
nent Limit ontology, that is used to reduce the amount of           2. The concept of monetary authority, that also is a legal
capital used for requirements checking, in cases that perma-           person, and used to define BACEN;
nent assets exceed a certain limit.
                                                                    3. The concepts for classification of institutions into com-
    The RWA group considered the division for risk man-
                                                                       pliant or not-compliant to specific regulatory norms;
agement mentioned in the first section, resulting in differ-
ent ontologies for Market Risk, Credit Risk and Opera-            Contextualized Monetary Amount Ontology for the defi-
tional Risk. An additional ontology Banking Book Risk               nition of a generic context concept, and also:
 1. The contextualized monetary amount concept is a spe-                                   RWAMINT                    RWAMPAD        is derived from
                                                                                                                                                              Sm
    cialization of FIBO Foundations monetary amount con-                                   (int. model
                                                                                           approach)
                                                                                                                      considering
                                                                                                                       Sm factor
                                                                                                                                        product of
                                                                                                                                                             factor

    cept, something that has a currency and an amount, and          RWAMINT
                                                                                has part

                                                                                                              is derived from is derived from
    that additionally has a context (uses FIBO Foundations         components
                                                                    (omitted)
                                                                                               is derived from maximum of        product of

    has currency, has amount and has context properties);                                        maximum of
                                                                                                                                                            relative
                                                                                                                                                              time
 2. The financial system governance context concept, that                            market
                                                                                                           RWAMINT
                                                                                                          considering
                                                                                                                                      RWAMPAD
                                                                                                                                      (standard            dependant

    specializes context, and also involves a monetary au-
                                                                                    risk RWA                                          approach)              factor
                                                                                                           Sm factor
                                                                                   component
    thority governing and constraining the behavior of a fi-                                                                                    has part
    nancial institution at a specific moment in time (uses
    FIBO Foundations is governed by and constrains prop-             OB Market Risk
                                                                     OB Foundations
                                                                                              contex-
                                                                                             tualized           market            reported            RWAMPAD
    erties).                                                         generalization          monetary
                                                                                             amount
                                                                                                               risk RWA            market
                                                                                                                                  risk RWA
                                                                                                                                                     components
                                                                                                                                                       (omitted)
                                                                     custom relationship
  The contextualized monetary amount concept is used to
represent amounts of cash related someway to a financial
                                                                                       Figure 2: Market Risk Ontology
system governance context, thus it is the major definition of
OntoBacen for addressing CQ3.
                                                                  the smallest (by comparing the has amount data property);
Market Risk Ontology                                              in the other cases, where there is only the standardized ap-
                                                                  proach, this latter is the one to be reported.
The main goal of this ontology is to provide a way to eval-          The market risk ontology defines the concepts men-
uate the market risk exposure by using at least one of the        tioned before as specializations of contextualized monetary
approaches available. Its semantics translates the business       amount. A general market risk RWA concept is defined, so
rules needed to obtain the market risk RWA (risk weighted         that it encompasses any market risk evaluation approach, be-
assets by market risk exposure).                                  ing naturally specialized by the two approaches previously
   Figure 2 shows its main concepts and their relationships       mentioned, and by an additional concept for the approach
using a notation similar to VOWL (Lohmann et al. 2014),           that was chosen to be reported to BACEN.
where concepts are represented as circles (filling colors indi-
                                                                     The intermediate results used in the evaluation of the mar-
cate modules), relationships (properties) as plain-line arrows
                                                                  ket risk RWA are conceptualized as specializations of an ad-
and generalization relationships as dotted-line arrows.
                                                                  ditional concept market risk RWA component. Finally, the
   The first important thing to note is that there are two        Sm factor concept is classified as a specialization of rel-
possible appoaches to evaluate the market risk RWA, the           ative time dependant factor, defined by Factors ontology
standardized approach (called RWAMPAD) and the inter-             and whose semantics define that its value is dependant of
nal model approach (called RWAMINT). Both of these ap-            the amount of time elapsed from a specific date (in this case,
proaches have more specific concepts that are omitted here        the market risk model transition date).
for a matter of simplicity.
   In both cases, financial institutions must verify their mar-
ket risk exposure by the standardized approach, because
                                                                  Capital Requirements Ontology
even the internal model approach depends on the standard-         There are different capital requirements specified by the BA-
ized. In addition, they are not required to have (or to use)      CEN regulations, such as minimum requirements for tier
an internal model, but in the cases that both approaches are      1 capital and reference capital. The latter is the most gen-
implemented, one of them must be chosen.                          eral (and relevant) definition of capital, so that this require-
   To opt for the internal approach, the institution must show    ments rules was chosen as the first to be implemented by
to BACEN that the proposed model actually maps the mar-           the Capital Requirements ontology. For the implementa-
ket risk efficiently and that it is consistent with the regula-   tion of capital requirements rules related to more specific
tions and norms. When opting for this model, things get a bit     concepts, such as tier 1 capital, some efforts will be needed
messy, because in this case, some conservative constraints        in the construction of ontologies for the Capital module,
for the evaluation of the RWA must be considered.                 described in the beginning of this section, and working in
   Firstly, a market risk model transition factor (defined as     progress at the moment of writing.
Sm) must be considered. This factor assumes the value of             The main idea of this ontology is to compare the risk
90% in the first year of the transition, and 80% after that.      weighted assets with some liabilities composition, defined in
This weighting factor is then applied to the standardized ap-     this case as reference capital, and that is mainly composed
proach, producing an intermediate result, the standardized        by reserves and shareholder’s equity. To define the concept
approach considering Sm factor. From the results obtained         of risk weighted assets, it is necessary to consider all types
by both the application of the internal model approach and        of risk (such as the market risk mentioned before), aggregat-
the standardized approach considering Sm factor, the greater      ing these multiple risk types as a general and single concept.
of these is defined as the internal model RWA.                    For that, all ontologies of the RWA module must be avail-
   Independently of the values for the market risk RWA ob-        able; as already mentioned before, at this moment the capital
tained by different approaches, institutions must choose one      requirements ontology is considering only market risk as a
of them to report BACEN. OntoBacen’s current implemen-            risk type.
tation chooses, in cases where the two models are evaluated,         The minimum required reference capital can be deter-
 Financial Institutions Ontology    Capital Requirements Ontology
                                                                          reference                                                                            4.Distribute terms
                  ref. cap.                          is derived from        capital
                                                                                                 time
                                                                                               interval
                                                                                                                                           .txt (NL)              and rules in
    ref. cap.                                           product of                                                      Art.I
                    limit           minimum                              requirement          dependant
   limit non-
                 compliant           required                               factor              factor                                 2.Self-contained,          modules by
  compliant
  institution
                 institution        reference
                                                            reported
                                                                                                                Input:                     complete              subject matter
                                      capital
                                                             market                                          Bacen norms                  sentences
                            is reduced                      risk RWA                                                                                                       .sbvr
                                                                                                                                                                          .sbvr
            depends on           by
                                                                            reported
                                                                             RWAs
                                                                                            capital
                                                                                          ontologies
                                                                                                                                                                         .sbvr
  depends on positive                     is derived from
   negative                                                               (other types
              margin                         product of
    margin   (dummy)
                                                         has part            of risk)                          1.Follow                 3.Extract terms and
   (dummy)
                                contex-
                                                       risk
                                                                    has part      defined permanent           references                   rules to SBVR
             margin
                               tualized
                                                     weighted                  somehow by    limit                                                                         .owl
                                                                                                                                                                          .owl
           over requi-
                               monetary
                                                      assets                     (dummy)   ontology              ref.
                                                                                                                                X          .sbvr (SNL)                  .owl
                               amount
             red ref.                                 (RWA)                                                       X
             capital                                                                                                                                               5.Convert SBVR
    OB Foundations
                               has part
                                                               reference
                                                                                            defined
                                                                                         somehow by            6.Manipulate                 for each module             to OWL
    OB Capital Requirements                          has        capital                    (dummy)             namespaces,                       (steps 6-9)         (formal logic)
                                                     part
    OB RWA Ontologies
    OB Capital Ontologies             ref. capital                                excess of                       imports,
    generalization                     for RWA
                                                         is reduced by
                                                                                  permanent                    cardinalities,                  7.Generate
    custom relationship
                                     comparison                                     assets
                                                                                                                 labels, etc.                                            Input:
                                                                                                                                               individuals            Operational
                                                                                                              Enrich semantics                 with custom
                                                                                                                  by adding                                           capital limit
                Figure 3: Capital Requirements Ontology                                                                                         application            report file
                                                                                                                SWRL rules.                      (Jena +
                                                                                                                    .owl                        SPARQL)                   .xml
mined from the risk weighted assets, as depicted by the de-                                                       +SWRL
pendency relationship between these concepts in Figure 3.
                                                                                                                                                    .rdf
This minimum requirement amount is given by applying a                                                       TBox
                                                                                                                                                                    9.Get answers
numerical factor (reference capital requirement factor) to                                                                                                             with new
                                                                                                                                                                      knowledge
the RWA, whose value decreases yearly (11% before 2016,                                                       ABox
9.875% at 2016, 9.25% at 2017, 8.625% at 2018 and 8% af-                                                                        8.Infer new axioms by
                                                                                                                                  using an OWL and
ter 2018). This fixed time interval dependancy is represented                                                                     SWRL compatible      new                 ?
as an specialization of the concept time interval dependant                                                                        inference engine
                                                                                                                                                      axioms

factor of the Factors ontology.
   Before this comparison between the reference capital and                                                      Figure 4: OntoBacen construction and usage steps
its minimum requirement could be done, the excess of per-
manent assets must be discounted from the capital, resulting
in an additional concept for comparison between capital and                                                  In the first step, it is needed to follow reference chains
RWA: reference capital for rwa comparation. This excess is                                                present in such norms, to construct, in a second step, seman-
determined by additional business rules, omitted here, be-                                                tically complete and self-contained sentences in natural lan-
cause they are in the scope of the Permanent Limit ontol-                                                 guage (Portuguese), by cutting and pasting portions of the
ogy, not yet constructed.                                                                                 original text.
   Another important concept definition is that of margin                                                    After that, in the third step, the self-contained sentences
over required reference capital, which is given by the differ-                                            are interpreted in order to achieve a first level of formality,
ence between the capital component, considering any nec-                                                  identifying and representing its terms and rules with SBVR
essary deductions such as the excess of permanent assets,                                                 (structured natural language). Note that there isn’t a SBVR
and the minimum required capital. From the margin over                                                    structured vocabulary for Portuguese; in this sense, relation-
required reference capital, one can determine if a financial                                              ships and rules are translated to English so they can be based
institution is compliant with the capital requirements verify-                                            on SBVR-SE (SBVR Structured English), but terms (con-
ing if its value is non-negative, analogous analysis could be                                             cepts) are kept in their original form.
made to determine if the institution is non-compliant (nega-                                                 Marinos, Gazzard, and Krause 2011 proposed the creation
tive margin).                                                                                             of a tool for the manipulation of SBVR vocabularies with
   Given these final considerations, concepts like reference                                              auto-completion and highlighting features, work that later
capital requirement compliant and reference capital require-                                              evoluted to SBVR Lab 2.04 , a tool freely available on the
ment non-compliant can be defined (shown as part of an ex-                                                Web; this tool was used to help achieving the goals of the
ternal ontology in Figure 3), which indicate the compliance                                               third step.
(or not) of some Brazilian financial institution to BACEN’s                                                  The fourth step begins with the possession of the SBVR
prudential regulation at a specific time.                                                                 vocabulary; its terms and rules are distributed in a set of dis-
                                                                                                          tinct vocabularies, mainly by considering their subject mat-
                                                                                                          ter, what inevitably demands interpretation and expertise of
                          Construction and Usage                                                          the domain; secondly, we take into account technical con-
The nine steps for developing and using OntoBacen are                                                     siderations, in order to achieve, for instance, a higher degree
shown in Figure 4. The six first steps are for the ontology                                               of disjointness between vocabularies, and thus minimizing
construction, while the last three are for its usage. BACEN’s                                             the number of relationships between terms of distinct sets.
prudential regulation is the input to this methodology, and is                                            Other important issue involves the detection of core terms,
available as a set of .pdf files written in Portuguese, that are
                                                                                                             4
copied to an easily editable format, such as text files.                                                         See: http://www.sbvr.co/.
those that are extensively related to other terms, and should                         
                                                                                       
be organized in such a manner that could be easily shared                               ...
                                                                                                                                  Reference Date
                                                                                                List of Reported Limits
between multiple modules.                                                              
                                                                                                                           Legal Person Identifier
   All these initial steps involves human interpretation and                                                Reference Capital
manual activities to be accomplished; they demand famil-                                ...     List of Parameters (Account Code = 100) Account
                                                                                                                                    Value
iarity with Brazilian legal writing, as the BACEN’s norms                              
are written similarly to any other Brazilian law document                               




                                                                          List of Accounts
(legalese), and also require prior knowledge about its subject                          
                                                                                        
matter, since these norms aren’t designed to be educational.                            ...
   The fifth step is the conversion of these multiple SBVR                              
vocabularies to OWL 2.0, generating the ontology modules.                               
                                                                                        
Some works in the literature address the conversion between                            
these two languages without semantics loss, however a more                            
detailed description is beyond the scope of this paper. Kar-
povic and Nemuraite 2011 worked in the field, resulting in
                                                                                             Figure 5: Example of limit report XML file (DLO)
the creation of a conversion tool freely available on the Web,
called s2o5 . The initial step for the creation of OntoBacen
OWL files used this tool6 .                                             a numerical identification code, and an amount of money
   In the sixth step, the initial OWL files obtained from s2o           (Brazilian reais).
are subjected to manipulations in order to complement and                  A Java application was developed to do the XML deseri-
enrich their semantics. For that, the Protégé7 software was           alization, that also used Apache Jena framework (with some
used to:                                                                help of SPARQL queries), for the automatic instantiation of
                                                                        the individuals to be later used in conjunction with Onto-
• Add or update namepaces and ontology imports;                         Bacen. The final result is a set of RDF files, following the
• Include some cardinality restrictions not captured in the             same modularization approach used in the ontology creation
  SBVR vocabularies phase;                                              phase.
                                                                           From now on, all components required for the reasoning
• Add labels and other annotation properties useable for                phase are ready. The reasoning can be done through a spe-
  documenting the ontology (in Portuguese and English);                 cific module, subsets of modules, or even all of them. In
• Create SWRL rules to allow the inference of additional                this phase, an inference engine compatible with SWRL rules
  axioms, including the use of its built-in functions for math          must be used; for the test cases presented in this paper, Pellet
  and date operations.                                                  (Sirin et al. 2007) was used for such a task.
                                                                           Finally, by using the set of inferred axioms, one can
   At this point, each OWL file is the final version of an on-          get the answers to the proposed competence questions, for
tology, concluding the terminological component (TBox) of               instance: a Brazilian financial institution complies to BA-
the system.                                                             CEN’s prudential regulation in a determined context, if it is
   The main reason to adopt such approach is because ma-                classified as capital requirement compliant in that context.
nipulating a large vocabulary such as the BACEN’s pruden-                  Notice that each module can answer some limited and
tial regulation, is made quickly by just listing its terms and          specific questions, for instance: the Market Risk ontology
rules in text files than formalizing all them in ontology de-           can only determine the degree of exposure to market risk,
velopment tools. In this sense, for OntoBacen’s initial de-             and that isn’t sufficient to verify the compliance or not to
velopment phase, described in this paper, only small subsets            BACEN’s prudential regulation; the presented competence
of the identified concepts were subjected to the formal on-             questions have a higher level of complexity, and need some
tology engineering process (step 6).                                    reasoning over all modules of the ontology so that they can
   For the construction of the assertion component (ABox),              be answered.
the input artifact for the definition of instances of the on-
tology classes (individuals) is the DLO8 , a XML report file                                                  Test Cases
that Brazilian financial institutions must submit to BACEN,
briefly depicted in Figure 5.                                           For testing the proposed knowledge system capabilities, a
   This file, containing the data required for the possible             standard example of the DLO was used, as provided by BA-
assertions which one can infer by the use of OntoBacen,                 CEN. From there, three additional test cases were created
is available in accordance with a XML Schema similar to                 by altering elements of the XML file, so that their instantia-
accounting, where each structure is composed basically of               tion could be automatically done by the custom application
                                                                        mentioned in the construction and usage section.
   5
      See: http://s2o.isd.ktu.lt/about.php.                                Table 1 shows the relevant input data of the four test cases,
   6
      It was necessary to apply a simple syntax transformation algo-    in millions of Brazilian reais, and for a matter of simplicity,
rithm in this step, whose details are beyond the scope of this paper.   the market risk RWA models were consolidated by its com-
    7
      See: http://protege.stanford.edu.                                 ponents, as it was shown in Figure 2.
    8
      DLO is an acronym for Demonstrativo de Limites Opera-                According to the information shown in Table 1, OntoBa-
cionais in Portuguese, and stands for operational limit statement.      cen can apply business rules by using an inference engine
compliant with OWL and SWRL rules, in order to answer if            tive margin over the required reference capital and therefore
the institutions in each case are compliant or not with BA-         the conclusion that it is not adherent to the norms.
CEN’s capital requirements regulations, considering their              Case 3 has both models implemented too, but the internal
exposure to market risk.                                            approach indicates the lower risk exposure (being reported),
                                                                    not sufficiently low to break the barrier of the standardized
  Case                    1         2         3         4           approach weighted by the Sm factor (90% in this case be-
  Reference Date          2015      2015      2016      2016        cause the model transition was done in less than a year).
                          Jan 1     Jan 1     Jan 1     Jan 1       Additionally, the reference date is now at the year of 2016,
  Mkt. Risk Model         N/A       2014      2015      2014        when the reference capital requirement decreases from 11%
  Transition Date                   Jul 1     Jul 1     Jan 1       to 9.875% of the RWA, and finally results in a handily pos-
  Reference Capital       2139      1000      1000      1000        itive margin over the required capital, concluding that this
  Excess of perma-        0         500       0         100         case is compliant.
  nent assets                                                          In the last case, number 4, the market risk approaches dif-
  RWAMPAD                 382       5000      5000      15000       fer greatly from one another, in such a manner that even the
  RWAMINT                 N/A       6000      4750      10000       Sm factor being of 80% (since the model transition hap-
                                                                    pened more than a year before the reference date), the in-
                Table 1: Test cases input data                      ternal model broke the barrier of the standardized approach
                                                                    weighted by Sm, so that the final RWA value by the inter-
  Case                    1         2         3         4           nal model will be the same of the barrier. As in this case
  Sm Factor               N/A       90%       90%       80%         the internal model will assume 80% the value of the stan-
  RWAMPAD (con-           N/A       4500      4500      12000       dardized approach, OntoBacen will choose it for being the
  sidering Sm)                                                      lower one. The minimum required reference capital is then
  RWAMINT (con-           N/A       6000      4750      12000       evaluated from the resulting RWA and compared with a mi-
  sidering Sm)                                                      nor value, which brings to a negative margin and the conclu-
  Reported Market         RWA       RWA       RWA       RWA         sion of non-compliance to BACEN’s capital requirements
  Risk RWA                MPAD      MPAD      MINT      MINT        regulations.
  Reported RWA            382       5000      4750      12000          All test cases executed the mentioned inferences in few
  Reference Capital       11%       11%       9.875% 9.875%         seconds, by using Pellet reasoner within Protégé, so that
  Req. Factor                                                       computational performance was adequate, since this isn’t a
  Min.     Required       42        550       469       1185        real time problem. The time for loading required ontologies
  Reference Capital                                                 from the Web was approximately thirty seconds.
  Ref. Capital for        2139      500       1000      900            OntoBacen currently deals with very general and aggre-
  RWA comparison                                                    gated concepts, so that performance was not a great con-
  Margin over Req.        2097      -50       531       -285        cern yet. However, as the level of detail (and data) increases,
  Reference Capital                                                 to deal with all data at once could be a performance issue,
                                                                    given the exponential nature of reasoning systems; this is
  CQ4: Ref. Capital       Yes       No        Yes       No
                                                                    another reason to consider modularity, alongside with dis-
  Limit Compliant?
                                                                    tributed reasoning, as a primary design requirement for mod-
       Table 2: Test cases inference steps and results              eling this domain.

   Case 1 is the default example provided by BACEN9 . In                                       Conclusions
this case, only the standardized market risk approach is used,      This paper presented an alternative technical approach for
so that it is necessarily the reported one, and the reference       dealing with risk management: instead of the standard spe-
capital is more than five times higher than the reported RWA,       cialized systems, we propose to use ontology-based tech-
with a highly positive margin over the required reference           nologies together with a knowledge-based system.
capital, resulting in the inference of such institution as com-        Our proposal provides an open knowledge reference to
pliant to the capital requirements.                                 address issues of this domain, freely available in the Se-
   In case number 2, both models are implemented, but the           mantic Web10 ; its semantics provides a formal representa-
standardized model indicates a lower risk exposure than the         tion of rules established by BACEN’s prudential regulation,
internal model, and as OntoBacen is configured to choose            and also a computational artifact that along with automated
the minimum exposure approach (this isn’t obligatory), the          reasoning can provide answers to the user.
standardized approach is chosen to be reported. This institu-          By the use of such approach, any Brazilian financial in-
tion has a high amount of permanent assets, so that the refer-      stitution that needs to report accounting and risk indicators
ence capital is halved when reduced by the excess of perma-         to BACEN by using an XML operational limit statement
nent assets, making the minimum required reference capital          (which has only syntactical and structural constraints, with-
higher in comparison with this amount, resulting in a nega-         out formal semantics), could verify its semantic consistency
                                                                    before submission, or even generate semantically consistent
    9
      The operational limit statement XML files are available at:
                                                                      10
http://www.bcb.gov.br/fis/pstaw10/leiaute limitesDLO.asp.                  URI: http://lti.pcs.usp.br/⇠filipe.polizel/OntoBacen/.
 content, avoiding mistakes and delays that can bring even-        [Abi-Lahoud, OBrien, and Butler 2013] Abi-Lahoud,           E.;
 tual penalties and losses.                                         OBrien, L.; and Butler, T. 2013. On the road to regulatory
    Finally, for the effective success of such solution, modu-      ontologies: Interpreting regulations with sbvr. AICOL.
 larity must play a central role in its design from the begin-     [BACEN 2014] BACEN. 2014. Regulação prudencial. Re-
 ning to the end, allowing financial institutions to take advan-    trieved from https://www.bcb.gov.br/?REGPRUDENCIAL,
 tage of computational features such as distributed comput-         last access on 2015 Apr 12.
 ing and avoiding to handle massive amounts of knowledge           [Berners-Lee, Handler, and Lassila 2001] Berners-Lee, T.;
 at once, given the exponential computational complexity of         Handler, J.; and Lassila, O. 2001. The semantic web.
 logical reasoning algorithms.                                      Scientific American.
                                                                   [BIS 1997] BIS.         1997.       Core principles for ef-
                      Further Work                                  fective banking supervision.                 Retrieved from
 This work intends to further explore the BACEN regulations         http://www.bis.org/publ/bcbs30a.pdf, last access on
 in order to define business rules for other risk types, such       2014 Aug 8.
 as credit and operational risk. Besides, the ontologies for       [BIS 2012] BIS.         2012.       Core principles for ef-
 capital definition will be created so that the reference capi-     fective banking supervision.                 Retrieved from
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 levels, such as tier 1 capital requirements.                      [BIS 2013b] BIS. 2013b. Regulatory consistency assess-
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