Enterprise / Operational Surrender Guide IT Audit Overseer City National Bank California Set-forth Polytechnic University, Pomona Execution surrender guide (ERM) is a referring-toly new training that convergencees on fulfilling, analyzing, mentoring, and material all material surrender collocatees (e. g. , trustworthiness, traffic, liquidity, operational surrender collocatees). Operational surrender guide (ORM) is a subset of ERM that convergencees on fulfilling, analyzing, mentoring, and material operational surrender.
The sentiment of this tractate is to expound what execution surrender guide is and how operational surrender guide fits into the ERM framework. In our omission, we examine what is simponderous to fall in the ERM / ORM environment balance the proximate 5 years. Introduction As the Internet has end of age, companies entertain been rethinking their trust types, kernel strategies, and target customer bases. “Getting wired,” furnishs trustes after a while new opportunities, but brings new surrenders and conjecture into the equation. Misguide of surrender can propel an elephantine absorb.
In fresh years, trust has conversant coagulated, kindred surrender reversals that entertain emanationed in material financial dropping, lower in portion-outholder treasure, detriment to union reputations, dismissals of elder guide, and, in some befallrences, the very alienation of the trust. This increasingly surrendery environment, in which surrender misguide can entertain fearful consequences, mandates that guide adopt a new spent proerratic perspective on surrender guide. What is Execution / Operational Surrender Management? Clearly, there is a mutuality between powerful surrender guide and a knowing trust.
Over interval, a trust that cannot handle surrender powerfully procure not thrive and, possibly miss. A disastrous effect foreclosure could be the union’s enunciateed. Rogue marketingrs scant balancesight and diffuse dominates entertain destroyed old polite-recurrent arts in a very near interval. But, historically, surrender guide in polite-balanced the most lucky trustes has tended to be in “silos”—the bond surrender, the technology surrender, the financial surrender, the environmental surrender, all handled inconsequently in detached compartments.
Coordination of surrender guide has usually been non-existent, and identification of emerging surrenders has been iazy. This tractate espouses a fresh concept—enterprise-remote surrender guide—in which the guide of surrenders is mixd and coordinated opposing the integral construction. A cultivation of surrender certifiedness is created. Companies opposing a remote crosssection of industries are inception to machine this powerful new systemology. 1 Execution / Operational Surrender Guide At earliest sight, there is abundantly consonance between operational surrender guide and other collocatees of surrender (e. . , trustworthiness, traffic, liquidity surrender, etc. ) and the machines and techniques applied to them. In veritableity, the principles applied are approximately selfsame. Both ORM and ERM must fulfill, esteem, abate and mentor surrender. However, at a spent constructive flatten, there are coagulated differences, ranging from the surrender collocatees themselves to the skills ask-fored to comaspect after a while operational surrender. Operational surrender guide is reasonservicecogent inception to indicate the proximate face of separation of urbane surrender guide.
Should attacheds be serviceservicecogent to enunciate lucky ORM programs, the proximate plod procure be for these attacheds to mix ORM after a while all other collocatees of surrenders into verily execution-remote surrender guide frameworks. See Exhibit 1 for an illustration of an ERM / ORM constructional construction figurative of the banking zeal: ERM Construction Chart CEO Order Surrender Director (ERM) Economic Principal (Planning) & Surrender Transfer Order Surrender Adherent Committee Vary Program Trustworthiness Surrender * Traffic Risk* Operational Surrender (ORM)* Urbane Compliance
IT Bond and Trust Continuity Urbane Surrender Evaluation (Audit) • Note – the material categories of surrender to which financial services attacheds surrender themselves are trustworthiness surrender, traffic surrender and operational surrender. Not surprisingly, financial services attacheds’ capaciousst surrender concentrations—trustworthiness surrender and traffic surrender are most powerfully handled. Exhibit 1 2 Why Execution / Operational Surrender Management? There are manifold reasons ERM / ORM functions are entity recurrent after a whilein corporations. subjoined are a few of the reasons these functions are entity recurrent.
Organizational Superintendence Two orders entertain freshly emphasized the consequence of surrender guide at the construction’s primary flattens. In October 1999, the National Association of Urbane Directors released its Recital of the Blue Ribbon Commission on Audit Committees, which recommends that audit committees “indicate and use intervally, convergenceed advice that is obedient to material accomplishment esteems and to the key surrenders they balancesee. ” The recital set-forths that the chair of the audit committee should enunciate an agenda that recognizes “a occasional criticism of surrender by each indicative trust ace. In January 2000, the Financial Executives Institute released the emanations of a superpurpose on audit committee powerfulness. Respondents, primarily main financial officials and urbane dominatelers, ranked “key areas of trust and financial surrender” as most material for audit committee balancesight. In imponderous of polite-balancedts surrounding fresh urbane scandals (e. g. , Enron, etc. ), and the increasing adherent and regulatory convergence on surrender guide, the percentage of companies after a while ceremonious ERM systems is increasing and audit committees are comely spent complicated in urbane balancesight.
The UK and Canada entertain set forth favoring legitimate exactments for audit committee balancesight of surrender evaluation, disappearance, and guide which are remotely not spurious as best practices in the U. S. Body of Problem The body of dropping and contact of operational surrender and droppinges to age is unamencogent to disown. Based on years of zeal dropping record-keeping from notorious sources, capacious operational surrender-kindred financial services droppinges entertain averaged polite in abundance of $15 billion year-by-year for the spent 20 years, but this barely reflects the capacious notorious and apparent droppinges.
Research has yielded approximately 100 singular bearing droppinges elder than $500 pet each, and balance 300 singular droppinges elder than $100 pet each. 1 Exhibit 2 is a listing of material operational droppinges. Interestingly plenty, the materiality of these droppinges entertain befallred in financial services, which expounds the zeal’s inherent convergence on operational surrender guide specially in the area of asset-jurisdiction typeing and treasure guide types to handle surrenders in the greatly irresolute principal traffics zeal of derivative trading and hypothesis. The 1 Hoffman, Douglas G. , Managing Operational Surrender (New York: John Wiley & Sons, 2002), p. xvi. 3 Top Operational Surrender Losses Union Coagulated Financial Institutions and Others BCCI Sumitomo Corporation Tokyo Shinkin Bank Banca Nazionale del Lavoro Daiwa Bank Barings Non-Financial Institutions: LTCM Texaco, Inc. Cendant Corporation Dow Corning St. Francis Assisi Reason Mettlgesellschaft Owens Corning Fiber Glass Orange County Atlantic Richfield Kashima Oil Showa Shell Prudential Securities Drexel Burnham Lambert General Motors Phar Mor Dropping Totality $20 pet. Initial Estimates $17 billion $2. 9 billion $2. 3 billion $1. 8 billion $1. 1 billion $1 billion $4 billion $3 billion $2. 9 billion $2 billion $2 billion $1. billion $1. 7 billion $1. 6 billion $1. 5 billion $1. 5 billion $1. 5 billion $1. 4 billion $1. 3 billion $1. 2 billion $1. 1 billion Age 2001 1991 1996 19901991 1992 19831995 1995 1998 1984 19851998 1994 1999 19911993 1980s1990s 1994 19861990 1994 19891993 1994 19981993 1996 1992 Description Terrorists hijacked lewd interchangecogent airliners and crashed them into the World Dealing Center. Balance 2000 lives lost. Countshort trustes contacted. Regulators seized encircling 75 percent of The Bank of Trustworthiness and Commerce International’s $17 billion in resources in a material injury. Sumitomo Corporation incurred colossal droppinges through abundanceive trading of copper.
The handler of the Imasato shoot not-genuine 19 safeguard diploma, which were used to breed money for accoutre traffics. Bygone employees repeat impure to conspiring to order $5 billion in distrusted loans to Iraq. Dropping due to distrusted trading by an employee. This catastrophic dropping has beend a benchmark for operational surrender. Losses due to bankruptcy of dual dominate and checks and balances. Colossal traffic droppinges due to indiffuse type guide and indiffuse dominates at Long Term Principal Management. Pennzoil sued Texaco alleging that Texaco “wrongfully interfered” in its merger traffic after a while Getty.
Largest and longest-running totalitying injury in narrative. Bygone adherents conspired to expand hues. The union agreed to pay settlements to 18 women who implied confront implants made them ill. Bond injury befallrence in which Martin Frankel allegedly stole as abundantly as $2 billion from this reason. Dropping due to favor of oil accoutre contracts. Settlement of asbestos-kindred claims. Largest mob surrender collocate befallrence in financial narrative. Largest investment dropping eternally registered by a municipality. Settlement of North Slope oil royalties difference after a while Alaska. Disguised droppinges on FX eager contracts.
Major oil refiner in Japan faced droppinges from eager vogue contracts. Settled totality of securities injury after a while set-forth and federal regulators. Bygone employees filed a collocate enjoyment aid charging the union after a while injury, divulsion of trust and carelessness. Heavy droppinges suffered due to 3 strikes. A bygone principal of the attached defrauded in an insolvency contrivance. Exhibit 2 Source: Hoffman; Managing Operational Surrender 4 Increasing Trust Risks After a while the increasing despatch of vary for all companies in this new era, elder guide must traffic after a while manifold abstruse surrenders that entertain tangible consequences for the construction.
A few forces currently creating conjecture are: • • • • • • • • Technology and the Internet Increased worldremote two-of-a-dealing Free marketing and investment worldremote Abstruse financial instruments Deregulation of key industries Changes in constructional constructions from downsizing, reengineering, and mergers Increasing customer expectations for proceeds and services Spent and capaciousr mergers Collectively, these forces are critical material vary and creating an increasing surrender in the trust environment.
Regulatory The interdiplomatic regulators distinctly purpose to promote banks to enunciate their own proprietary surrender esteemment types to assess regulatory, as polite as economic, principal. The habit for banks should be a tangible diminution in regulatory principal, and a spent weighate allocation of principal vis-a-vis the veritable surrender confronted. In December 2001, the Basel Committee on Banking Supervision submitted a tractate “Sound Practices for the Guide and Supervision of Operational Risk” for illustrate by the banking zeal.
In enunciateing these probe practices the Committee recommended that banks entertain surrender guide arrangements in establish to fulfill, esteem, mentor and dominate operational surrenders. While the curb in this tractate is purposeed to use to interdiplomaticly erratic banks, plans are to polite-balancedtually use this curb to those banks reputed indicative on the reason of dimension, abstruseity, or arrangementic consequence and to smaller, short abstruse banks. Regulators procure polite-balancedtually guide ordinary defiant evaluations of a bank’s strategies, policies, procedures and practices addressing operational surrenders.
The tractate indicates an defiant evaluation of operational surrender procure inurbane a criticism of the subjoined six bank areas:2 • • Rule for assessing balanceall principal coextension for operational surrender in narration to its surrender profile and its inner principal targets; Surrender guide rule and balanceall dominate environment powerfulness after a while i-elation to operational surrender exposures; 2 Basel Committee on Banking Supervision, Probe Practices for the Guide and Supervision of Operational Risk, (Basel, Switzerland: Basel Committee on Banking Supervision, 2001), p. 1. 5 • • • • Systems for mentoring and recitaling operational surrender exposures and other befallrences resources weighations; Procedures for intervally and powerful decomaspect of operational surrender exposures and polite-balancedts; Rule of inner dominates, criticisms and audit to indicate candor of the balanceall surrender guide rule; and Willingness of operational surrender disappearance efforts. Traffic Factors Traffic veritableityors to-boot play an material role in motivating constructions to weigh ERM / ORM. Generic portion-outholder treasure guide and ERM / ORM are very abundantly linked.
Today’s financial traffics establish tangible premiums for suitably contravention hues expectations. Not contravention expectations can emanation in critical and swift refuse in portion-outholder treasure. Research guideed by Tillinghast-Towers Perrin rest that after a while all else entity resembling, constructions that achieved spent compatible hues than their peers were rewarded after a while materially higher traffic valuations. 3 Therefore, for urbane adherents, managing key surrenders to hues is an material disunite of portion-outholder treasure guide. The unwritten sentiment of surrender guide has repeatedly convergenceed on resources and iability kindred issues or inner dominates. However, “traditional” surrender polite-balancedts such as lawsuits and regular miserys may entertain insignificant or no contact on destroying portion-outholder treasure compared to other strategic and operational exposures—such as customer call-for nearfall, competitive pressures, and absorb balanceruns. One description for this is that unwritten surrender hazards are referring-toly polite implicit and handled today—not that they don’t subject. Managers now entertain the occasion to use machines and techniques for unwritten surrenders to all surrenders that interest the strategic and financial objectives of the construction.
For non-publicly marketingd constructions, ERM / ORM is valuservicecogent for manifold of the selfselfsame reasons. Rather than from the perspective of portion-outholder treasure, ERM / ORM would furnish handlers after a while a generic balancesentiment of other material items such as specie stream surrenders or stakeholder surrenders. Regardshort of the constructional conceive, ERM / ORM can be an material guide machine. Urbane Governance Defense athwart operational surrender and droppinges streams from the primary flatten of the construction—the consultation of fearfulctors and adherent guide. The consultation, the guide team that they employ, and the policies that they enunciate, all set the sound for a union.
As guardians of portion-outholder treasure, consultations of fearfulctors must be acutely attuned to traffic reenjoyment to indirect tidings. In veritableity, they can discover themselves castigated by the notorious if the reenjoyment is critical plenty. As figuratives of the portion-outholders, consultations of fearfulctors are under obligation for device 3 Tillinghast-Towers Perrin, Execution Surrender Management: Trends and Emerging Practices. (The Institute of Inner Auditors Research Foundation, 2001), p. xxvi. 6 subjects referring-to to urbane dominateance, including but not scant to contrast the aspect for the framecomaspect and reason for execution surrender guide.
Right now, operational surrender guide is a “hot topic” of examineion for regulators and in consultationrooms opposing the US. In the suscitate of the 2001 releases from the Basel Surrender Guide Committee, banks now entertain excite recognition as to the regulatory aspect on the ask-for for regulatory principal for operational surrender. Meanwhile, portion-outholders are certified that there are media to fulfill, esteem, handle, and abate operational surrender that add up to billions of dollars eternallyy year and recognize usual, low-flatten droppinges and to-boot inusual but catastrophic droppinges that entertain veritablely wiped out attacheds, such as Barings, and others.
Regulators and portion-outholders entertain already signaled that they procure obstruct fearfulctors and adherents totalityservicecogent for managing operational surrender. Best-Practice Elder handlers ask-for to promote the enunciatement of mixd arrangements that height several traffic, trustworthiness, liquidity, operational and other surrenders generated by trust aces in a compatible framecomaspect opposing the art. Consistency may beend a indispenscogent predicament to regulatory encomium of inner surrender guide types.
An environment where each trust ace calculates their surrender detachedly after a while incongruous rules procure not furnish a meaningful balancesight of attached-remote surrender. The increasing abstruseity of proceeds, linkages between traffics, and implicit services offered by balanceall portfolio proceeds are forward constructions inland bannerizing and integrating surrender guide. Omission It seems unobstructed that ERM / ORM is spent than another guide fad or academic hypothesis. We love that ERM / ORM procure beend disunite of the guide rule for constructions in the advenient.
Had ERM / ORM rulees been in establish during the spent two decades, a estimate of the operational surrender debacles that took establish may not entertain befallred or would entertain been of shorter body. Companies are inception to see the service of compensating themselves from all types of implicit surrender exposures. By fulfilling and mapping surrender exposures throughout the construction, a union can conglomerate on healing those exposures that can do the most detriment. After a while an reason of surrenders, their injustice, and their enumerate, a union can incrow to solutions; be it fostering, transferring, sharing, or avoiding a disuniteicular surrender.
Our designs on what procure fall in the ERM / ORM environment in the proximate 5 years are: In the proximate 5 years, it is simponderous that companies procure no longer sentiment surrender guide as a specialized and elementary zeal: the guide of bond or exotic exvary surrenders, for solicitation. The new avenue procure 7 guard handlers and employees at all flattens sensitized to and concerned encircling surrender guide. Surrender guide procure be coordinated after a while elder guide balancesight and eternallyyone in the construction procure sentiment surrender guide as disunite of his or her job. The surrender guide rule procure be rectilineal and genericly convergenceed.
All trust surrenders and opportunities procure be seasoned. In the proximate 5 years, the use of bottom-up surrender tributes procure be a banner rule used to fulfill surrenders throughout the construction. The self-tribute rule procure compromise eternallyyone in the union and exact singular aces to convergence and recital on the threats to their singular trust objectives. Through the selftribute rule, the construction procure be serviceservicecogent to recognize dropping implicit and surrender dominate by trust, by avail courage and by effect. The singular row handler procure start to recognize the dropping implicit in his or her own ruleing arrangement.
In the proximate 5 years, the use of top-down scenario anatomy procure be another banner system used to fulfill surrenders throughout the construction. Top down scenario anatomy procure indicate the surrender implicit for the integral attached, the integral trust, construction, or portfolio of trust. By its very essence, it is a high-flatten fidelity and cannot get into the bottom-up transaction-by-transenjoyment surrender anatomy. For illustration, owing Microsoft has a campus of spent than 50 buildings in the Seattle area, earthquakes are a surrender. 4 In the spent, Microsoft looked at silos of surrender.
For illustration, they would entertain looked at resources bond when they weighed the surrenders of an earthquake and design encircling compensating equipment and buildings. However, using scenario anatomy they are now preamble a spent holistic perspective in weighing the surrender of an earthquake. The Microsoft surrender guide order has analyzed this misery scenario after a while its advisors and has attempted to quantify its veritable absorb, preamble into totality how surrenders are correlated. In the rule, the order attested surrenders in indivisibleization to resources detriment, such as the subjoined: • • • • • • 4
Director and official jurisdiction if some mob consider guide was not correctly skilful. Key personnel surrender Principal traffic surrender owing of the attached’s poverty to marketing. Worker atonement or employee service surrender. Supplier surrender for those in the area of the earthquake. Surrender kindred to dropping of traffic portion-out owing the trust is interrupted. Michel Crouhy, Dan Galai, and Robert Mark, Making Execution Surrender Guide Payoff (New York: McGraw-Hill, 2001), pp 132-133. 8 • • Research and enunciatement surrenders owing those activities are interrupted and effect delays befall.
Product rule surrenders owing the union cannot rejoin to customer inquiries. By using scenario anatomy, guide has attested a estimate of surrenders that it rule not entertain otherwise and Microsoft is now in a ameliorate aspect to handle these surrenders. The advenient ERM / ORM machines such as surrender tribute and scenario anatomy procure back companies in fulfilling and healing the materiality of these surrenders. In the proximate 5 years, companies procure be using inner and exterior dropping befallrencesbases to seize befallrences that may object droppinges to the union and the veritable droppinges themselves.
This befallrences procure be used in inherent types that procure device the implicit droppinges from the several surrender exposures. This befallrences procure be used to handle the totality of surrender a union may be procureing to choose. In the proximate 5 years, companies procure tabulate principal to singular trust aces based on operational surrender. By stringing operational surrender principal totality to the sources of that surrender, singulars after a while surrender optimizing bearing procure be rewarded and those after a whileout suited surrender practices procure be penalized.
In the proximate 5 years, inner audit procure beend polite-balanced spent convergenceed on how surrenders are handled and dominateled throughout the union on a rectilineal reason. Inner audit procure be under obligation for recitaling on candor, exactness, and lucidity of the union's integral surrender guide rule. In indivisibleization, Inner Audit procure be complicated in ensuring the fitness of the union's principal tribute and allocation rulees. Furthermore, audit procure rule perennial amendment of surrender guide and dominates through the sharing of best practices.
In the proximate 5 years, guide procure be looking for singulars who are skilled in surrender guide. Professional designations such as the Bank Administration Institute's Certified Surrender Professional (CRP) and the Advice and Audit and Dominate Association's Certified Advice Bond Overseer (CISM) procure manifest dexterity in the surrender guide area and procure be in call-for. In the proximate 5 years, exterior auditors procure be exactd to recital on the procureingness and powerfulness of a union’s surrender guide program.
These companies procure be exactd to make-known the end and essence of surrender recitaling and/or esteemment arrangements in their annual recitals. Overall, companies procure be ameliorate aspected in the proximate 5 years to traffic after a while the generic end of execution-remote surrenders. By machineing the ERM / ORM rule now, companies procure start to maximize their balanceall surrender profile for competitive habit. 9 Bibliography Barton, Thomas L. ; Shenkir, William G. ; Walker, Paul L. Making Execution Surrender Guide Pay Off. New Jersey: Financial Times / Prentice Hall, 2002. Basel II Mandates a Nest http://web2. infotrac. galegroup. co Egg for Banks” US Banker. (July 1, 2002) 48. July 2002. BITS. BITS Technology Surrender Transfer Gap Anatomy Tool. Washington, D. C. : BITS, 2002. Bock, Jerome T. , The Strategic Role of "Economic Capital" in Bank Management, Wimbledon, London: MidasKapiti International, 2000. Trust Banking Board. RAROC and Operating Risk. Washington, D. C. : Urbane Adherent Board, 2001. Trust Banking Board. Surrender Guide Structure. Washington, D. C. : Urbane Adherent Board, 2001. Consultative Document Operational Risk. 2001.
Bank for Interdiplomatic Settlements and Basel Committee on Banking Supervision. July 2002. http://www. bis. org/publ/bcbsa07. pdf Crouhy, Michel; Galai, Dan; Mark, Robert, Surrender Management. New York: McGraw-Hill, 2001. “Elements of a Lucky IT Surrender Guide Program”. Gartner. (May 2002. ) 9. July 2002. http://www. gartner. com/gc/webletter/bindview/issue1/ggarticle1. html Ernst & Young, Integrated Surrender Guide Practices. Unpublished PowerPoint slides, Ernst & Young: 2000. Hively, Kevin; Merkley, Brian W. ; Miccolis, Jerry A. Execution Surrender Management: Trends and Emerging Practices.
Florida: The Institute of Inner Auditors Foundation, 2001. Hoffman, Douglas G. Managing Operational Risk. New York: John Wiley & Sons, Inc. , 2002. “In Brief: Ferguson Urges Investing in Surrender Control”. American Banker. (March 5, 2002) 1. July 2002. http://0proquest. umi. com. opac. library. csupomona. edu James, Christopher, RAROC Based Principal Budgeting and Accomplishment Evaluation: A Occurrence Study of Bank Principal Allocation. Pennsylvania: The Wharton School, 1996. Jameson, Rob; Walsh, John, “The Inherent Contenders,” Surrender Magazine, (November 2000). 6. July 2002. http://www. financewise. om/public/edit/riskm/oprisk/opr-soft00. htm Bond Zeal - Participating companies: Allianz, AXA, Chubb, Mitsui Sumitomo, Munich Re, Swiss Re, Tokio Marine and Fire, Xl, Yasuda Fire and Marine and Zurich. Bond of Operational Surrender Under the New Basel Accord. Bond Industry, 2001. Lam, James, “Top Ten Requirements for Operational Surrender Management” Surrender Guide (November 2001) July 2002. http://0-proquest. umi. com. opac. library. csupomona. edu Marks, Norman, “The New Age of Inner Auditing” The Inner Auditor (December 2001) 5. July 2002. http://0-proquest. mi. com. opac. library. csupomona. ed McNamee, David; Selim, George M. Surrender Management: Changing the Inner Auditor’s Paradigm. Florida: The Institute of Inner Auditors Research Foundation, 1998. National Association of Financial Services Auditors. “Enterprise Surrender Management,” National Association of Financial Services Auditors. Spring 2002. 12-13. netForensics is a Web standing that examinees those regulations that dominate advice bond in financial services, healthcare and dominatement. http://www. netforensics. com/verticals. html 10 Ong, Michael; “Why plague? Surrender Magazine, (November 2000). 6. July 2002. http://www. financewise. com/public/edit/riskm/oprisk/oprcommentary00. htm Practice Advisory 2100-3: Inner Audit’s Role in the Surrender Guide Process. March 2001. The Institute of Inner Auditors. July 2002. http://www. theiia. org/ecm/guide-frame. cfm? doc_id=73 Santomero, Anthony M. , Interchangecogent Bank Surrender Management: an Anatomy of the Process. Wharton School, 1997. Pennsylvania: The Probe Practices for the Guide and Supervision of Operational Risk. 2002. Bank for Interdiplomatic Settlements and Basel Committee on Banking Supervision.
July 2002. http://www. bis. org/publ/bcbs86. htm The Financial Services Roundtable, Guiding Principles in Surrender Guide for U. S. Interchangecogent Banks. Washington D. C. : The Financial Services Roundtable, 1999. Verschoor, Curtis C. Audit Committee Briefing – 2001: Facilitating New Audit Committee Responsibilities. Florida: The Institute of Inner Auditors, 2001. Working Tractate on the Regulatory Treatment of Operational Risk. 2001. Bank for Interdiplomatic Settlements and Basel Committee on Banking Supervision. July 2002. http://www. bis. org/publ/bcbs_wp8. pdf 11