=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==
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 shoulddetailed 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 tal concept can be decomposed in more detailed definitions. http://www.bis.org/publ/bcbs230.pdf, last access on Therefore, the Capital Requirements ontology could be 2014 Aug 8. enriched in order to consider all possible types of risk, and [BIS 2013a] BIS. 2013a. Principles for effective risk data capital requirements rules could be evaluated in additional aggregation and risk reporting. levels, such as tier 1 capital requirements. [BIS 2013b] BIS. 2013b. Regulatory consistency assess- Other issue concerns the integration capabilities of the ment programme (rcap) assessment of basel iii regulations proposed ontology. In order to address that, additional se- in brazil. mantic alignments can be done between OntoBacen and other ontologies, while the work on financial ontologies [Engel et al. 2013] Engel, P.; Hamscher, W.; Shuetrim, G.; (FIBO, FIRO, etc) progresses. Another possible approach vun Kannon, D.; and Wallis, H. 2013. Extensible business for this question would be consider additional ontologies as reporting language (xbrl) 2.1. possible semantic foundations, such as a mathematics ontol- [Grüninger and Fox 1995] Grüninger, M., and Fox, M. S. ogy to express some of the relations identified in OntoBa- 1995. Methodology for the design and evaluation of on- cen (derivation of concepts by differences, maximums, etc). tologies. As these goals are achieved, additional efforts can be done [Guarino 1995] Guarino, N. 1995. Formal ontology, concep- in such a way to deepen the concepts definition for each sub- tual analysis and knowledge representation. International domain that composes the governance of a financial system Journal of Human and Computer Studies 43:625–640. risk management, increasing the proposed system granular- [Karpovic and Nemuraite 2011] Karpovic, J., and Nemu- ity and thus allowing it to treat additional risk management raite, L. 2011. Transforming sbvr business semantics into questions (or even accounting). To this end, a lot of work in web ontology language owl2: Main concepts. In Proceed- the interpretation of an extensive set of BACEN regulation ings of the 17th international conference on Information and documents should be done, and as the ontology evolve in Software Technologies (IT 2011), 231–238. depth of details, new modular considerations must be taken [Lohmann et al. 2014] Lohmann, S.; Negru, S.; Haag, F.; and into account, such as those discussed in this paper. Ertl, T. 2014. Vowl 2: User-oriented visualization of ontolo- After the construction of the modules proposed in the gies. In Proceedings of the 19th International Conference specification section, this work also aims to evaluate the ap- on Knowledge Engineering and Knowledge Management, proach using a more realistic case study, by applying Onto- EKAW ’14, 266–281. Springer. Bacen rules with the data of a real Brazilian financial insti- tution, that is publicly available via balance sheets and risk [Marinos, Gazzard, and Krause 2011] Marinos, A.; Gazzard, reports, or even by collecting more detailed data using the P.; and Krause, P. 2011. An sbvr editor with highlighting and operational limit statement XML sent to BACEN by some auto-completion. institutions. [Niles and Pease 2001] Niles, I., and Pease, A. 2001. To- wards a standard upper ontology. In Proceedings of the 2nd International Conference on Formal Ontology in Acknowledgements Information Systems (FOIS 2001). ACM. See also Jaime Sichman partially financed by CNPq, Brazil, proc. www.ontologyportal.org. 303950/2013-7. [OMG 2008] OMG. 2008. Semantics of business vocabulary and business rules (sbvr), v1.0. References [Sirin et al. 2007] Sirin, E.; Parsia, B.; Grau, B. C.; Kalyan- pur, A.; and Katz, Y. 2007. Pellet: A practical owl-dl rea- [Abi-Lahoud et al. 2013] Abi-Lahoud, E.; Butler, T.; soner. Web Semantics: Science, Services and Agents on the Chapin, D.; and Hall, J. 2013. Interpreting regulations with World Wide Web archive 5:51–53. sbvr. In Proceedings of RuleML (2)’13. 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 andReference 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 normsare written similarly to any other Brazilian law document these two languages without semantics loss, however a moreList 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