EDM Council Membership Update Developments in Enterprise Data Management Michael Atkin Managing Director, EDM Council 31 March, 2014 Confidential Query Layer (SPARQL, SQL, CQL, NQL, Natural Language Processing) Mechanism for perform structured queries over linked datasets Data Quality Strategy Fit-for-Purpose - completeness, coverage, conformity, consistency, accuracy, duplication, timeliness. Data Quality Management - profiling, testing, cleansing, QA process and implementation of business rules Shared Vocabularies (dictionary, taxonomies, metadata) Adoption of common financial language. Must ensure that concepts are both precise and based in legal certainty Mapping to Common Meaning Alignment of data meaning from one format to another. The goal is consistency of meaning across repositories. This includes mapping of business concepts, mapping of relationships and format transformation Identification (LEI, ISIN) Unique and precise identification of the financial instruments and business entities that form the baseline components of our industry Location Layer (URL, URI, DNS) Web-based location identifiers enable data to be accessed across the web. Namespace management is included Ontology (OWL, UML, 1st order logic, modal logic) Representation of data to record the logical relationship between terms in the context of business reality Messaging Layer (XML, CSV, SWIFT, Web Services) Transactions are communicated to involved parties via messaging. Examples are FIX, ISO 20022, FpML for derivatives, MISMO for loans, XBRL for balance sheet data Corporate Actions Copyright 2014 EDM Council, Inc. Positions and Transactions Market Data and News Transport Layer (HTTP, TCP/IP, FTP) Facilitation of computer-to-computer communication in alignment with W3C and IETF standards Information Technology and Operations Governance Management of architectural approach, data distribution platform, transformation processes and data integration Analytical Layer Database Types: instrument, entity, transaction, holdings | Core Processes: issuance, trade, servicing, retirement | Analytical Inputs: cash flow, obligations base on role performed; ownership/control and positions [the essential ingredients for scenario-based analysis and ability to understand links/relationships] Reference Data Data Management Governance Management of data management strategy, organizational model, funding model, governance structure, organizational alignment and operational culture Data Management Infrastructure BCBS 239 Context • 2008 Crisis: Inability to model contagion (who finances who, who is linked to who, what are the obligations of complex financial instruments) • Senior Banking Supervisors Group: Observations on Developments in Risk Appetite Frameworks and IT Infrastructure (intractable relationship between data and risk management and definition of control environment) • BCBS 239: Principles of Risk Data Aggregation and Reporting (governance, content infrastructure and data quality as mandatory objectives) Confidential Copyright © 2014 EDM Council Inc. 3 Basel RDA Self-Assessment • Banks understand the importance of the Principles and are committed to enhancing data aggregation and risk reporting capabilities • “… many banks are facing difficulties in establishing strong data aggregation governance, architecture and process (initial stage). Instead they resort to extensive manual workarounds which are likely to impair risk data aggregation and reporting” • BCBS specifically calls out the need to: – – – Upgrade risk IT systems (emphasis is on harmonization of data definitions across the information lifecycle) Improve data quality capabilities (focus on improvements in accuracy, completeness, timeliness and adaptability in times of stress) Enhance governance (emphasis on data ownership and accountability for risk data quality) • BCBS and FSB “… expect banks identified as globally systemically important (G-SIBs) to comply with the Principles by 1 January 2016” • Basel Committee strongly suggests that “… national supervisors apply the Principles to banks identified as domestically important (D-SIBs) three years after their designation as such by their national supervisors” Confidential Copyright © 2014 EDM Council Inc. 4 RDA Self-Assessment • Principle Two (data infrastructure) – Lowest rating among the 11 Principles – 70% are materially non-compliant on integrated data taxonomies and glossaries – 60% are material non-compliant on data production and control across data lifecycle • Principle Three (data quality) – Third lowest rating among Principles – 40% are materially non-compliant on IT alignment across repositories (generation of enterprise risk) – 60% are materially non-compliant on level of dependency on manual data reconciliation processes • Principle Six (adaptability) – Second lowest rating among Principles – 83% are materially non-compliance on ability to meet ad hoc requests Confidential Copyright © 2014 EDM Council Inc. 5 Specific Data Issues and Priorities Gov. Finding/Problem Flexibility: systems are not flexible enough to adapt/perform scenario-based analysis IT Integration: IT systems are not integrated across linked processes (alignment across repositories) control across linked processes Manual Processes: too much dependence on manual processes eliminate manual reconciliation processes Data Standards: inconsistent data taxonomies, dictionaries, metadata (inability to harmonize, integrate and compare) adopt common financial language Data Policy: decentralized/undocumented data policies and procedures Framework: lack of formal and documented RDA frameworks SLA: insufficient service level standards for RDA processes (measurement criteria) DQ Management Process: Lack of comprehensive data quality policies and procedures (definition of core data attributes, documentation of production process, quality metrics) Quality: insufficient data quality reconciliation and management (logic checks, tolerance levels, root cause analysis, standard dimensions, executable business rules) Data Lifecycle: control throughout the lifecycle of data (data inventory, transformation mapping, crossreferencing, authoritative sources) Interdependencies: failure to take into account the interdependencies between processes X Copyright © 2014 EDM Council Inc. DQ X X X X X X X X X X Accountability: clear data owners with accountability mechanism (demarcation of responsibility, coordination of requirements among business, IT and risk) strong governance with clear accountability Audit: need higher internal standards for audit of data aggregation and reporting Documentation: Inadequate documentation/distribution Confidential Infra. 6 X X X X X X X X X X X X X X X X X X X X X 2014 Questionnaire (expectation) • Governance Principle – – – – • Is the RDAR framework established (clear accountability) Has it been approved by executive management and fully resourced Is the framework documented, verified by stakeholders and aligned with capability Are RDAR limitations (and methods of redress) known at top-of-house Data Infrastructure Principle – Are standard identifiers, metadata and taxonomies established and integrated across the enterprise and for all functions and processes – Is lineage controlled across the full data lifecycle including integration into existing IT environments • Data Quality Principles – – – – Confidential Are core risk concepts (dictionary) consistently defined across the enterprise Is data reconciled to source systems Is the balance between manual and automated systems appropriate and justified Is the data complete (including off-balance sheet content), timely (produced in near real time), accurate (able to be validated against precise rules), traceable (across the data production process), usable (without transformation) and adaptable (useful for on-demand and ad-hoc analysis) Copyright © 2014 EDM Council Inc. 7 BCBS Task Force (US and UK) Activity Summary/Components Participants 1. Communication (shared): adoption of common lexicon and shared framework; clarification of ambiguities and determination of adherence • 2. Governance (benchmark): Establish governance program; document and approve policies and standards; implement operating model; enforce and audit OCC/Treasury and Federal Reserve • 3. Data Dependencies (benchmark): critical risk functions critical measurements critical business attributes authorized data domains logical data models physical repositories transformation processes US/CN: AIG, Bank of America, Bank of New York, Citi, GE Capital, Goldman Sachs, JPMorgan, Morgan Stanley, Royal Bank of Canada, State Street, Wells Fargo UK: Barclays, HSBC, Lloyds, Royal Bank of Scotland, Standard Chartered Prudential Regulatory Authority • EY, McKinsey, IIF and EDM Council 4. Material Areas (shared): requirements for resolution, liquidity risk, counterparty risk, CCAR, loans/MBS, derivatives, credit exposure, trading exposure, positions, limits, market concentration 5. Measurement Criteria (shared): current to endstate evaluation; incremental deliverables 6. Standard Infrastructure (benchmarking): internal process for reconciliation of identifiers, data taxonomies, classification schemes; (shared) adoption of industry-wide standards and process for cross referencing/mapping Confidential Copyright © 2014 EDM Council Inc. 8 BCBS Capability Framework A common lexicon ► Governance framework for data management is closely aligned to DMM (include alignment with risk and finance governance mechanisms) ► There is good alignment to framework Development. (Alignment to risk as well) ► Data policy and standards are addressed in DMM ► Financial model (funding) for RDA is broader than data, but DMM has components that will ensure the data funding issues are covered ► Culture and communication is shared with risk awareness; most likely will be driven by the risk organization Page 9 ► Nearly all of the Data Aggregation components of RDA will be covered in DMM. ► Architecture will be shared with technology 2/13/2014 ► Process controls and security controls are elements of ‘partnership’. These will be the responsibility of other groups (operations; business continuity; info-security). These are discussed in DMM, with respect to the importance of a DM Program being ALIGNED to other key stakeholders BCBS Risk Data Aggregation & Risk Reporting Principles Industry Roundtable ► Data Quality considerations are a key component of the DMM and will be addressed Reverse Engineering Flow BCBS239 Prioritization Approach Reverse engineer starting with critical risk functions backwards to data source CR Critical Risk Measurements Critical Risk Functions CBEs Critical Business Entities Persisted Data Repositories (Physical) Data Standardization Authorized Data Domains (Logical) Need to harmonize data across disparate physical repositories with clear lineage to source Data Flow Derivatives Transparency Microcosm of the data challenge: complex instruments; highly customized; links to underlying instruments; links to entities; multiple participants/roles; standard identifiers missing; fragmented trading and reporting processes According to the CFTC • “ISDA taxonomy is not granular enough” • “Data is not aligned for exotics and bespoke instruments and doesn’t map to ISDA taxonomy” “Complex data compiled from 20 SEFs on a continually changing basis” • “Each department has a different analytical objective” • “Data is all over the place with no consistency in reporting of values” • “Must be able to compare data across multiple SDRs” • “Data is not clean enough to perform analysis and we can’t reconcile manually” • • “USI alpha swap is not associated with beta and gamma, can’t link swaps based on multiple criteria” “We need a mechanism for mapping, understanding data relationships and unraveling process flows” • “Can’t unravel trades to analyze notional amounts .. can’t look at entity roles … can’t compute cash flows” • • Confidential “Data needs to be standardized and aligned to common meaning” Copyright © 2014 EDM Council Inc. 11 OFR/FRAC (Recommendations) Risk Subcommittee Data Subcommittee • • Collateral Mapping Instrument Database – – – – Adopt ontology to fulfill legislative obligation Evaluate FIBO as the instrument database Follow LEI model of collaboration Use derivatives as test case of viability (OFR CFTC FSB/EMIR FSOC collaboration) – Build and populate map of collateral flow – Use liquidity map as model – Mechanism is critical for Identification of critical roles and obligations to track • Macro-Prudential Stress Testing – Current stress testing analysis is for microprudential assessment – Aggregate CCAR data to fulfill DFA mandate on macro-prudential oversight – Use CCAR to assess impact of scenariobased shocks • Reporting Modernization – Migrate from report-based to data-centric reporting – Working group to create business case and build inventory of reports/data overlap – Implement POC (rule-based requirements, adopt standards, define technical and operational capabilities) – Investigate entitlement requirements and mechanisms to avoid duplicate data collection Confidential Research Subcommittee • Forensic Investigation expertise “on call” • Accounting expertise on staff (state contingent cash flow, fair valuation, etc.) • Systemic implications of insurance sector Copyright © 2014 EDM Council Inc. 12 Systemic Risk (what keeps FSOC/ESRB up at night) • “Data challenges loom large” (Mary Miller, Undersecretary of Treasury for Domestic Finance) Issues of Importance – Short vs. long term funding (degree of interconnectivity and durability) – Shadow banking (funding without insurance) – Operational risk (#1 threat to the financial sector) • • • • • • Relationship between players (degree of complexity and interrelationships; more connections = higher risk) Flow of funds (direction, timing, concentration) Partial disruption = asymmetry = conservative decisions Cyber-security (very, very, very real threat; most likely malware) Internal fraud, sabotage, bad contractors Technology failure (poor design, bad testing, insufficient resiliency) – Counterparty risk (SSG Report) – “five years after the crisis, progress on timely and accurate counterparty risk has been largely unsatisfactory” – Derivatives and complexity of financial system (understanding relationships, interconnectivity, transitive exposure and contract terms are critical ) Confidential Copyright © 2014 EDM Council Inc. 13 Core Regulatory Initiatives • Dodd-Frank Act Title IV, VII, X, XIV = US framework for regulation of swaps markets, hedge funds, CFPB, mortgage, Volker Transparency • EMIR – European Market Infrastructure Regulation (EU version of Dodd-Frank Title VII on derivatives transparency). • Regulation AB2 = regulations on asset backed securities (unravel links between loan, tranches, pool, etc.). • FATCA = individual reporting of foreign accounts and FSI reporting of foreign financial accounts about US clients • UCITS = Undertakings for Collective Investment in Transferable Securities (EU Directive on simplification of prospectus and their expression using clear, accessible and standardized data). • AIFMD – Alternative Investment Fund Managers Directive (EU proposed law to provide more oversight and transparency to hedge funds and private equity). • Dodd-Frank Act Title I = the financial stability component (creates Financial Stability Oversight Council and OFR) Capital Risk/Stress • EU System of Financial Supervision = establishment of the European Systemic Risk Board (and ESFS) • Basel Principles for Effective Risk Data Aggregation and Reporting = implementation of a “data control environment” and healthy “risk appetite framework” within systemically important financial institutions • Basel III – global regulatory standard on bank capital adequacy, stress testing and market liquidity risk. • CCAR = Comprehensive Capital Analysis and Review (stress test methodology in the US; CCAR reporting is putting lots of pressure on data alignment and comparability. This includes the FR Y-9C (Bank Holding Company Capital Report) and FR Y14Q (detailed ‘show your calculation methodology work for BHC). This is the US version of Basel III. • Solvency II – EU Directive that harmonizes insurance regulation (requirements for capital reserve and reduction of risk of insolvency) – to be implemented January 2014. Harmonization • MiFID II – Revised Markets in Financial Instruments Directive (mostly about trading, but does require common instrument identification for consolidated pricing). • ACORD – Insurance standards development body (UK) likely to be mandated as the format for reporting. • Regulation SCI – SEC proposed Regulation Systems Compliance and Integrity (to ensure that core infrastructure is functional) • COREP = Common Reporting requirements (developed by Committee of European Banking Supervisors (CEBS) with the goal of developing a supervisory reporting framework based on common data standards and formats. • FSB Templates = Common Data Template for G-SIB’s seeking to harmonize the data compounding methodology for reporting. Copyright © 2014 EDM Council Inc. Confidential Data Management Maturity Model • Harmonized with CMMI/SCAMPI methodology • Capabilities defined with enriched evaluation criteria for “capability” and “maturity” • Alignment with Basel RDA Principles • Expected Version 1.0 release 2nd qtr ‘14 Data Management Maturity Model (DMM) Category DM Function Governance Data Content Mgt. Operations Platform and IT Process Area Elaboration Strategy Rationale for the data management program and long-term vision Business Case Justification for the investment and funding model DM Program Framework for sustainability Governance Management Operating model, policies and procedures Communication Mechanism to achieve buy-in Control Environment Data standards and common language Data Quality DQ strategy, measurement and remediation Information Lifecycle Lineage, data flow and controls DM Ecosystem Entitlement, permit to build, privacy, change management Architectural Framework Architectural standards and approach Integration Platform, storage, access and release management DMM Example (Data Management Program) Definition A Data Management Program is an organizational function dedicated to the management of data content … Purpose The purpose of a Data Management Program is to establish a sustainable process … Introduction The concept of managing “data as meaning” is not always well understood. For many organizations … Goals • Ensure that the Data Management Program is established and institutionalized … • Ensure that the Data Management Program is staffed to provide sustainable … Core Questions • Is the Data Management Function defined in a way that can be clearly understood … • Is the Data Management Function aligned with the strategy and organizational … Confidential Copyright © 2014 EDM Council Inc. Defines the process area Establishes why the process area is important and describes its intended purpose Extensive narrative to help stakeholders understand the objectives of the process area in real terms Summary of the management goals for each process area Top line questions that executive management should be asking about each process area 16 SCAMPI Methodology • Maturity Model Principles – Proven practices (in widespread use with consistent terminology) – Clarity between “required” concepts (what you are assessed against) vs. “informative” concept (designed to facilitate understanding) – Measurement of both “capability” (within a single process area) and “maturity” (across a set of process areas) • CMMI Structure – – – – – • Practice Statements – – – – Confidential Supported by organizational policy Implemented using standards and standard processes Defined resource and training requirements Clear responsibilities and involvement of stakeholders Control over the process and evidence of adherence “What” not “how” (does not specify an implementation) Unambiguous (no vague verbs, only one interpretation, complete statements) Supported by evidence (must be able to demonstrate capability) Level progression (capabilities are inherited from previous level) Copyright © 2014 EDM Council Inc. 17 Data Quality (interim report) • Survey sponsored and performed by DTCC (with help from Element22 and aligned with DMM) – DQ management is underway across industry (still in early stages, not formalized) – EDMC seven dimensions are being used as the common language about data quality (completeness, coverage, conformity, consistency, accuracy, duplication, timeliness) – Characteristics of Mature Programs • • • • • • • • Serve business requirements Focus on core data attributes Understand end-to-end data lifecycle Mandate use of authoritative source systems Apply consistent DQ business rules Perform root cause analysis and remediate at source Align with Basel RDA principles Seek to integrate multiple platforms (operational efficiency) – Measurement of Data Quality • • Confidential Align with business outcomes (client service, reporting comparability, process breaks, alignment with risk assessment) Quantitative measures (breach of SLA’s, vendor performance, internal consistency, symbology conflicts, duplicate identifiers, activity volume) Copyright © 2014 EDM Council Inc. 18 Governance: Three Deadly Sins 1. Maturity: Implementing governance structure before understanding of what we are governing (and why) 2. End-User Computing: Tactical, end-ofchain data fixes that become intractable 3. Data as Infrastructure: Failure to implement the underlying data foundation Confidential Copyright © 2014 EDM Council Inc. 19 10 Principles of Sustainable Governance 1. Executive Mandate 6. Data quality is the goal – but it is dependent on business requirements and measured against what users have at stake in their decisions. Adopting a sustainable data culture and getting people to behave is impossible without top-of-thehouse mandate. 2. Serve Business 7. Capture, verify and re-verify business requirements to align strategy with operational goals. 3. Process Understanding 8. 5. Confidential 9. Education is Essential Data content management is a new concept for everyone. It is not the same thing as data processing management. Standards Standards are essential for data harmonization. They are the key to integration. They will unify the industry. They are the legacy of the financial crisis. Authoritative Source Every reference data element must have a single authoritative source – and all copies must be identical to the authoritative source. Core Data Elements Not all data elements are created equal. Do the business forensics to identify critical attributes. Accountability is mandatory! Data Meaning Unambiguous shared meaning of the obligations of the contract is the key to everything. Learn to love the word ontology. Data is a manufactured product and we must understand how data flows from process-to-process. 4. Data Quality 10. Collaboration Data is foundational. It brings people from diverse areas together and promotes data collaborative sharing. This is about creating a shared vision. Copyright © 2014 EDM Council Inc. 20 Legend 2011 & 2013 Industry DMM Scorecard Quality 2011 2013 Quality Assurance Goals Corporate Culture Data Quality Framework Technology Platform and Integration Strategy Governance Model Architectural Framework Funding Sourcing Levels Standards and Procedures Operations Requirements Lifecycle 0 – does not exist 1 – project or ad-hoc 2 – business line 3 – enterprise 4 – measured 5 – optimized Financial Industry Business Ontology Goal of data harmonization and comparability established (common financial language aligned to meaning) Top Line Summary • Standard: FIBO Foundations and Business Entities through OMG architecture board and technical evaluation process (unanimous) • RDF/OWL: Documented and streamlined the technical migration from “requirements modeling” to RDF/OWL (pathway for expedited development) • Release Schedule: Development pathway defined and dependencies mapped • Repository and Access: Syntactic transformation to import FIBO into Adaptive Metadata Manager (interface design and access methodology) • Model Validation: Process defined for member review and validation (business meaning and externality review) • Use Cases: Substantial progress in demonstrating the various use cases for FIBO and inference processing (proving the practical application) • Technical Strategy: Positioned for long-term collaboration with financial institutions, academia and semantic processing companies (operational implementation, business rules, shared semantics, data visualization) Confidential Copyright © 2014 EDM Council Inc. 22 POC Activities and Use Cases Ensure FIBO Supports Industry Requirements • – – – – – – – Operational ontology (inference processing using RDF/OWL) Intersection of interest rate swaps, credit default swaps and business entities Classification and aggregation Data validation Alignment with messaging (FpML and FIXML Fact-based queries Transitive exposure analysis • Data Repository Alignment • Executable Business Rules – – Confidential • Derivatives Regulation W RuleLog and SBVR Liquidity Mapping – – – • Messaging Alignment – – – • Effective rates Sectorial detail Core liquidity concepts FpML for derivatives MISMO for mortgage securitization XBRL for COREP Data Model Integration – – – IBM/IFW BIAN Teradata • OFR Instrument Database (common reference point) • Internal Process Improvement • Valuation Process Support Copyright © 2014 EDM Council Inc. 23 Data Management Implications • Adopt standards-based infrastructure (common financial language is the top priority) • Basel BCBS 239 (RDA) obligations are firm (how to “do it right” vs. “do it quick” given deadline) • Scenario-based analysis (on demand, ad-hoc, adaptability) • Degree of interconnectedness is the most important criteria for financial stability analysis • Adopt standard measurement criteria for data quality, infrastructure alignment and governance • Derivatives are the front line of the regulatory data challenge • Collaboration with regulators on priorities and dependencies (knowledge gap exists) • Data flows and process alignment is as important as data quality Confidential Copyright © 2014 EDM Council Inc. 24 Contact Michael Atkin Managing Director, EDM Council (o) 301.933.2945 (m) 240.602.8390 atkin@edmcouncil.org www.edmcouncil.org Confidential Copyright © 2014 EDM Council Inc. 25 FIBO Development Scenario Reference Data (product) Semantics Domain Sub-Domain Class Dependency X (all Instruments) X Common Debt Terms X Phase 2 Bonds Listed Instruments X Equities Phase 3 Common Concepts Loans Common Concepts Derivatives X (FIBO 1.0) Major Milestones Indices and Indicators Rate Based Dependent on Indices X Credit Default Dependent on Common Concepts for Loans, Common Debt Terms and Indices/Indicators X Phase 4 Derivatives OTC OMG = in RDF/OWL; Beta = Model Reviewed by SMEs; Model = Modeled in Enterprise Architect; Initial = Not Yet Modeled X FX Confidential Model X Business Entities Common Concepts Beta X Phase 1 Foundations OMG Initial FIBO Development Scenario Reference Data (product) Semantics Domain Sub-Domain Class Dependency Structured Finance Dependent on Bonds and Mortgage Money Markets Includes Repo, Treasury, Government, Agency, Tax-Free, etc. Asset Dependent on Equities, Bonds and Common Debt Terms OMG Beta X Commodity X OTC X Phase 6 Derivatives Debt X Phase 5 Listed Instruments X Mortgage Collective Investment Vehicles X Exchange Traded Other General Purpose, Construction, Student, Miscellaneous X Dependent on Common Concepts for all Instruments X Rights and Warrants Dependent on Listed Instruments, Derivatives and Indices X Phase 7 Loans X Contracts for Difference Derivatives OMG = in RDF/OWL; Beta = Model Reviewed by SMEs; Model = Modeled in Enterprise Architect; Initial = Not Yet Modeled Confidential Model 27 Initial FIBO Development Scenario Market Data (time and date) Semantics Domain Class Dependency OMG Beta Temporal Component X Equity Pricing X Debt Pricing and Yields Debt Analytics X Debt Pool Analytics X CIV Temporal Terms X Future Phase Debt Temporal Terms X Loan Temporal Terms X Trading Status X Credit Rating Credit Status X Credit Temporal Terms OMG = in RDF/OWL; Beta = Model Reviewed by SMEs; Model = Modeled in Enterprise Architect; Initial = Not Yet Modeled Confidential Model X Common Terms Sub-Domain 28 Initial FIBO Development Scenario Process Related Semantics Domain Sub-Domain Class Dependency OMG Beta X Common Issuance Process Terms IPO, Other Equity Issue Processes, Primary Market Debt/Bonds Issuance Auction, Syndication, Other Issuance Processes Agency X Asset-Backed / Mortgage-Backed Issuance X Equity Issuance X Future Phase Securities Issuance X Non-Agency OTC Derivatives Transactions See OTC Derivatives Terms X Trade, Post-Trade, Clearing, Settlement X Securities Transactions X Payments Processing Positions and Holding Terms X Portfolio and Holdings OMG = in RDF/OWL; Beta = Model Reviewed by SMEs; Model = Modeled in Enterprise Architect; Initial = Not Yet Modeled Confidential Initial X Corporate Actions and Events Model 29 Industry Requirements FIBO Q1 2014 Development Process Review Readiness with SME Team Syntactic Transformation FIBO BCO/UML Model in Cameo/VOM FIBO BCO/UML Model in EA Happy EDM Council Determines Next FIBO SubDomain Release Not Happy FIBO Use and Maintenance in Cameo/VOM Perform Externality Review Semantic Enhancement Change or add No Validation with Instance Data Enhance? yes Consistency Testing/Repairs Yes Spiral implementation of enhancements Refactoring No Semantic Issues Correction Pass? No Yes Yes Submission to OMG Architecture Board No Build/Test OMG Submission No Yes OMG Public comments Changes 30 Development Version: 1/24/14 Change FIBO BCO No Final SME Review