IBM 000-181 : IBM WebSphere ILOG JRules BRMS V7.1 Application Development Exam
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Introduction to Interoperability for Digital Currencies
across the globe, valuable banks have mentioned the want for “interoperability” when discussing digital sovereign currencies (CBDC). but what is interoperability and why may still they pay consideration to it? also, even if a CBDC should be designed at a retail or wholesale stage, the bigger question is how it would have interaction with the rest of the world. earlier than they tackle the interoperability question, let us right now recap on the conception of valuable bank Digital Currencies (CBDC).
(figure 1 - conceptual illustration of CBDC at the crucial bank layer)
A CBDC is a time period for a 3rd edition of foreign money that might use an digital checklist or digital token to symbolize the digital sort of a nation's foreign money . CBDC can also be issued and managed at once by the relevant financial institution and will be used for a lot of functions by using individuals, organizations, and economic associations. even as the thought of imperative bank digital currencies (CBDCs) are essentially digital models of common fiat currencies and they understand funds does essentially take an electronic form. So how are they distinctive from average forex? traditional money is created via industrial banks during the fractional reserve banking methods, and the property and liabilities are held on the balance sheets of such banks and consumers .
CBDC in contrast, the legal responsibility would be held at the significant bank and which might be liable to challenge the digital token. The primary bank would deserve to maintain the reserves to again the legal responsibility and in idea, may disintermediate banks completely.
"A CBDC is a digital fee instrument, denominated in the country wide unit of account, which is an immediate legal responsibility of the significant financial institution, like money. It gives a brand new, digital kind of important financial institution money – a safe, impartial and ultimate contract medium that can extinguish all claims in a transaction."
(BIS, Agustin Carstens, 2021)
relocating back to the subject matter of interoperability, the G20 currently made go-border payments a priority  and interoperability is a crucial point to this considering. the area economic discussion board (WEF) additionally cited that the center of attention of their current work carried out by the Digital foreign money Governance Consortium (DCGC), which has produced eight policy frameworks to ebook trade and coverage-makers via one of the crucial most vital challenges, opportunities and choices involving CBDC and stablecoins additionally covered interoperability as of its key policy frameworks .
Interoperability for a CBDC in idea is the place it's going to be feasible to movement assets from one birthday party on one community to an additional on a very different network with some degree of commonality essential between both. the two parties should in idea understand that each other exists. This should be coupled with the required proof that the transaction has taken vicinity, which is facilitated through finality, which if utilized by way of blockchain platforms should still take vicinity at the smart contract level. For finality to take location, here's the place the notary will deserve to log off on a transaction. Finality can in apply work differently on diverse platforms, however as long as they've some way to show that a transaction has passed off, the community can be interoperable . As they now have lately viewed, a variety of jurisdictions are working on their own version of a CBDC and even as they each and every independently add value to their jurisdictions, the improved cost add is garnered via how distinct CBDC interoperate across distinctive borders.
in response to a contemporary look at carried out by using the bank for foreign Settlements (BIS), more than 70% of institutions are actively researching and setting up proof of concept for CBDCs. in fact, you may additionally argue that here is the key component in making CBDCs critical and effective in blockchain-primarily based finance . based on current research, they now have considered uncoordinated research and construction, this is raising interoperability considerations because of distinctive code languages, necessities and applicable regulatory systems, which can be all leading to the question on whether attainable technologies corresponding to blockchain may well be used in an integrated manner.
in order for interoperability to exist between different international locations, CBDCs will need to have a high degree of commonality (each technically and operationally) the place there can also be seamless degrees of interoperability, despite the fact, as have viewed within the early days of CBDC construction, the diploma of commonality is unlikely to be this high. This doesn’t suggest interoperability is unattainable though.
As stated by using Tom Mutton, director of the financial institution of England’s CBDC unit at Sibos, “Interoperability is critical, they ought to prevent fragmentation, [which] factors inefficiency and negative effects. even if it’s a retail CBDC or wholesale CBDC for funds platforms, interoperability is vital” . This sentiment is additionally shared through commercials banks and Florence Lubineau-Henric, Head of significant Banks insurance at BNP Paribas, Paris has argued interoperability is complicated to crack but may still be a prerequisite for a CBDC in the event that they are to be absolutely efficient and operational.
“it might look prudent for principal banks to trust coordinating their CBDC efforts carefully and introducing adequate flexibility into their CBDC designs to facilitate pass-border interoperability and standardization across CBDC implementations"(foreign financial Fund, 2020)
while digital currencies are a comparatively new theory and never general within the financial lives for citizens in most countries nowadays, it’s possible that they will play an important function in the future. in the near future, or not it's likely that many critical banks will put in force some kind of a digital ledger. Catherine Gu, the world CBDC Product Lead for Visa stated that in order for this to come to fruition, critical banks will need to select the tech stacks and design protocols that take advantage of experience for their materials, taking elements like governance, market necessities, expertise providers, compliance specifications, and nation-particular priorities into consideration . because the number of CBDCs increases and the network raises, each enjoyable CBDC will come with its personal design requisites and specifications, with distinct corporations, merchants and buyers all transacting on the identical network, expanding utility and resulting in decreasing cash spending. but this can make it difficult for go-border transactions.
in order for pass border payments using CBDC to work and performance optimally, there are a couple of challenges that need to be addressed. These challenges were highlighted returned in early 2020, the place the fiscal stability Board (FSB) initiated a study of XBPs (cross-border payments) in line with a request by way of the G20, which identified the challenges of existing XBP arrangements . The FSB reported that there have been seven friction elements for the go-border procedure which blanketed legacy know-how, confined working hours, complexity for compliance exams, fragmented messaging codecs, long transaction chains, vulnerable competitors and funding charges. Addressing interoperability will need to be navigated through these friction aspects if we're to see a a hit interoperable ecosystem for CBDCs.
"while most CBDCs will possible put into effect some variety of a digital ledger, it is not going that they all adopt the equal stack of applied sciences and protocols because of, as an instance, diverse governance, market requirements, expertise providers, and levels of monitoring and compliance requisites required through vital banks."
(universal funds Channel, 2021)
lamentably, the distinct digital ledger designs being proposed with the aid of distinctive countries will restrict the interoperability of CBDC networks which should be a key requirement for enforcing frictionless, move-border CBDC payments. including a novel expertise (i.e. Blockchain) and a sort of latest money corresponding to a CBDC, can additional complicate these challenges for referred to banks trying to stream these sorts of transactions.
To resolve these issues within an CBDC ecosystem, there is a necessity to translate present strategies with the aid of interlinking diverse and likely disparate CBDC techniques. Even earlier than the advent of CBDCs, the inner most sector has been investing in and testing new technologies to in the reduction of these frictions and constructing solutions. here is what the BIS could name “new multilateral platforms” and here is what Visa calls “international open networks”, each of which share a typical aim to enhance world cash circulation. reckoning on the design, primary banks don't seem to be immune from these frictions, and will primary banks continue to pursue their own native CBDC options, they're going to inevitably come across new interoperability hazards. with out a mechanism or framework to be sure CBDC interoperability, these risks might have wider implications for international move-border payments.
Digital Currencies on Blockchain structures
As crucial banks design their personal models of digital currencies already in existence, should still they leverage DLT (blockchain) solutions equivalent to Ethereum and Bitcoin, or should they be setting up the usage of their personal distinct interesting systems? To reply this query, they need to dive deeper into how blockchain options feature and assess if they meet the requirements for relevant banks leveraging their own digital currencies. CBDC through design, can also be managed on a digital ledger (which could either be on a blockchain or non-blockchain platform), which could raise the protection of payments between different associations, banks and individuals.
There are big adjustments between Bitcoin like decentralized blockchain based cryptocurrencies and fiat funds, similar to stability and regulatory potential. here's why such decentralized cryptocurrencies cannot be an choice for digital fiat money and hence why crucial banks all over the world were pursuing their own analysis into digital fiat cash (i.e. CBDC). by way of making use of blockchain based mostly CBDC, it has been cited that they could boost efficiency as neatly create extra cozy charge techniques . however, this know-how remains fairly nascent, fueled with controversy as a result of there are lots of challenges surrounding the technology corresponding to protection, throughput and scalability.
but what's blockchain? Blockchain is a distributed ledger technology (DLT) where cryptographic ideas and consensus algorithms are utilized to achieve decentralization, traceability, immutability, anonymity, transparency and security. on the core, decentralization is the primary function for this expertise, which is mentioned to reduce fees and enhance efficiencies. handiest established transactions are recorded on the blockchain and they're deemed to be immutable once they're validated by way of nodes. as soon as each transaction is validated (with timestamps), all nodes in the community can provide transparency throughout the consensus mechanism. This ledger is shared amongst all individuals in the community and cryptographic thoughts are applied to make certain that all data recorded can't be tampered .
however why use blockchain to tackle interoperability design considerations? they now have viewed a boom and hobby in cross-chain protocols that could ensure interoperability between blockchains, for this reason enabling the alternate of cost as well as assistance between quite a few networks. they have already witnessed a few public blockchain networks, together with Ethereum, focusing on interoperability and scalability, leveraging structures like Cosmos and Polkadot through inter-blockchain protocols (IBC). Others have worked on bridging mechanisms for blockchain conversation. Even deepest commercial enterprise blockchain networks equivalent to HyperLedger have recounted the more advantageous want for blockchain interoperability and are slowly moving toward leveraging public blockchain networks reminiscent of Ethereum. There are no single options when it involves this area as distinct protocols are working on their own solutions similar to 'Atomic Swaps' which is the mechanism to allow users to coordinate transactions throughout different chains by way of a peer-to-peer transaction, 'Relays' which allow wise contracts on a selected chain to investigate routine that have taken location on other chains, and 'merged consensus' which uses a relay chain to allow two-means interoperability.
Complemented with the merits of public decentralized chains, such protocols could potentially lay the groundwork for wider blockchain adoption in the CBDC space. it's already clear that blockchain platforms can assist interoperability between distinctive asset varieties via sensible contracts (programmable cash). this may facilitate the method of funds being recorded as tokens on blockchains which may lead to growing effective ecosystems when different property are additionally recorded as tokens. With cash and assets recorded as tokens, parties can create transactions that affect more than one trade concurrently.
"pass blockchain compatibility, enables distinctive blockchains to speak with one yet another with out the aid of intermediaries. What this skill is that blockchains sharing similar networks may be capable of transfer cost between each different"
(one hundred and one Blockchains, 2021)
If blockchain expertise were to be utilized, you could be able to list these assets to a definitive blockchain checklist and as mentioned previous, the smart contract code which is based on the blockchain would certain
integrity. this is able to be a large trade to what they see within the existing state of affairs present today, with out a should pinning reliance on third events to behave as they have promised. as a substitute, integrity of the whole system is guaranteed by means of the expertise, as a substitute of by using individual actors. moreover, we've already outlined that there are considerable protection advancements using blockchain based CBDCs over centralized payment programs. These advantages are twofold, there is no ‘honey pot’ because funds exists as tokens held via participants and therefore no centralized honey pots are targeted which can reduce the incentives for assaults. Secondly, there isn't any centralized aspect of failure. this is as a result of as facts is replicated throughout distinct participants for every transaction and every participant runs impartial nodes, there are no single facets of assault which may bring down the community.
present world Blockchain based CBDC development Efforts
distinctive international locations and central banks across the globe are exploring different blockchain protocols such as Corda, Ethereum and material. Some are exploring CBDCs via single entry aspects, others through bilateral links, and some the use of the hub and spoke model (or multilateral hyperlink). When it involves the BIS Innovation Hub tasks which are analyzing interoperability there are a few to dive into. we've undertaking Nexus (Singapore Centre) which is in keeping with the 'hub and spoke model' which appears at interoperability between three or more domestic FPS. Then they have project mBridge (Hong Kong) which makes an attempt to boost move-border funds via a standard platform for wholesale CBDCs. Then there is undertaking Dunbar (Singapore) which is looking to feature a standard platform for the change and issuance of CBDCs that in theory can also be maintained through distinctive principal banks and/or financial institutions. lastly, they now have undertaking Jura (Switzerland) which is asking at interoperability on privately-owned typical systems for separate sub-networks for wholesale CBDCs. but a lot of these aren't experimenting the usage of Blockchain solutions.
So what work is being performed with blockchain expertise? as an example, Corda is being experimented below challenge Japer (Canada) and E-Krona is adopted below challenge Khokha (Estonia) leveraging Quorum. Ethereum is additionally being researched in Australia. however as which you could see, diverse blockchain protocols are being researched in diverse jurisdictions and so move-border transactions will be a challenge as distinct blockchain based mostly CBDC networks will deserve to speak and alternate, ideally the usage of some kind of cross-chain protocol .
distinct blockchain protocols can also use distinct encryption, hashing and consensus algorithms, transaction constructions and block sizes which reasons standardization challenges. pass-chain interoperability is essential for diverse blockchain protocols. If the focus is only home payments, then move-chain interoperability may additionally not be beneath the design considerations for these international locations.
(determine 2 - conceptual blockchain architecture)
If a DLT had been to be regarded as part of the design of a CBDC, here high-degree layer diagram (see above) gives a conceptual illustration of the important thing constructing blocks: layer 1 protecting the core layer, layer 2 performing the backend utility layer, and layer three being the front-conclusion. the important thing takeaway is that the blockchain layer is on the core of this design and contains blockchain nodes and wise contracts. The position of this sediment is to supply right here activities:
smart contracts for issuance and redemption transactions
sensible contracts for payment transactions
Decentralized ledger block validation
upkeep of CBDC balances
Such blockchain prototypes may be developed both on ConsenSys or Hyperledger Besu, a permissioned commercial enterprise Ethereum blockchain the place the latter has been adopted by using the Inthanon-LionRock (IL2) venture. of their prototype, a couple of distinct tasks were working together, the place each and every changed into assigned a validating observe and each industrial financial institution turned into a participant having been assigned a node. both nodes are then augmented with an Orion transaction supervisor which is liable for enabling private verbal exchange between other nodes so that all members are not in a position to view information. For the applications of consensus, the validator nodes perform the function of agreement finality to the network participants with the aid of publishing the finalized transaction blocks onto the blockchain. It is this distinction that units apart the validator node to the commonplace nodes for the applications of consensus.
The lessons learned from the IL2 prototype has shown that DLT can enormously boost the velocity, decrease the charge and supply operational efficiencies and resiliency to complicated pass-border charge flows. It additionally stated that further resourceful modular options can aid allocate liquidity, get to the bottom of gridlock, provide aggressive FX, enforce compliance and regulatory oversight, and guide the integral future capabilities. besides the fact that children, there are limitations such as the reliance on privateness organizations to hold privateness throughout varied jurisdictions does not permit for utterly atomic PvP transactions. also, as there is no single entity or jurisdiction that can view the steadiness of all pending FX transactions; an highest quality liquidity rate reductions mechanism has yet to be found. finally, scalability and performance of DLT in dealing with giant transaction volumes will deserve to be assessed further if more jurisdictions or currencies are introduced onto the platform .
(figure three - illustration of the IL2 prototype stack layers)
On an extra observe, HSBC and IBM additionally currently introduced in December (2021) the successful trying out of an advanced token and digital wallet settlement skill encompassing direct transactions between two critical bank digital currencies (CBDC) in a hybrid cloud atmosphere, incorporating public and private clouds and on-premise information sources. The dispensed ledger design become in response to IBM's Hyperledger material and R3's Corda have been built-in the use of IBM analysis's Weaver interoperability tool . The experiment changed into designed and implemented inside a four-month period, and become brought up to be correctly accomplished throughout ledgers in aid of such a posh multi-asset transactional situation. This test validated the end-to-end transactional lifecycle covering CBDCs (minting and allocation), eBonds (delivery versus fee (DVP) throughout fundamental issuance and secondary trading and coupon payments), and foreign exchange (pricing and price versus price (PVP) contract) .
Can CBDCs be Interoperable on different Networks
in order for CBDCs to interoperate, can they be on different protocols? for my part, yes. diverse underlying systems may also be interoperable as long as they meet the minimal necessities of finality as mentioned previous. it's additionally essential that the interoperability protocols of other structures align with the precise-world use case of crucial banks, who will wish to be sovereign over determining no matter if a transaction in their foreign money has settled . the important thing aspect to highlight is that the crucial bank should still be able to manage finality, but this may also now not all the time be the case for each platform.
a further element to agree with how to ensure that as blockchain technology evolves, will it undermine the current compliance regimes of diverse international locations? The BIS has continued their research on this particular theme by detailing the distinct attributes of distinctive CBDCs preparations which examines the distinct coordination features of such an ecosystem with the aid of “designing frameworks which consist of technological, market structure and criminal aspects, aiming to facilitate move-border interoperability of distinct CBDCs from distinct jurisdictions . The mBridge mission is a cooperation between the BIS Innovation Hub Hong Kong Centre, the Hong Kong fiscal Authority; the financial institution of Thailand; the Digital currency Institute of the americans’s financial institution of China; and the principal financial institution of the United Arab Emirates .
based on the under illustration by the BIS, they have designed three separate fashions which study diverse mCBDC arrangements in line with right here:
mannequin 1 - mCBDC arrangement in keeping with suitable CBDC systems
model 2 - mCDBC arrangement in accordance with interlinked CBDC programs
model 3 - single mCBDC multi-currency system
(figure four - distinctive mCBDC fashions as per BIS study)
Visa have also get a hold of their own analysis on utilising a bridging framework referred to as customary funds Channel (UPC) can support in advertising a technically greater resilient and sound design mannequin for go-border payments. in line with the UPC design and CBDC infrastructure for cross-border transactions, a two-tier CBDC model would enable central banks to delate the initiatives for key provisioning to one or extra certificate authorities (CA) whose responsibility is to provision keys of the central bank as wallet providers . The wallet provide during this mannequin design is the entity can will entry the CBDC DLT and provide services related to the pockets and if required, provide end consumer custody.
The UPC facilitates payments the usage of the web via internet capabilities which they call the 'UPC hub' which is the gateway which receives cross-border payments from wallet provides and then sending them to the destination pockets. whereas the UPC hub is trusted to be all the time obtainable and process fee requests, its operation within every CBDC system is absolutely transparent through design to any entity. In essence, the UPC hub is a server or set of servers. At one aspect, Visa described the UPC hub as a form of generic correspondent bank. It touts the expertise of handiest wanting to provide id verification as soon as as opposed to the identification challenges of constructing numerous banking relationships. it may possibly even be setup below multiple channels, serving the UPC hub to enable pass border payments for a multitude of distinctive CBDCs, enabling interoperability .
while we've discussed that interoperability comes with merits, but that this is rarely without charges. Raphael Auer (foremost Economist at BIS) had stated all through one of his speeches on pass-border "multi-CBDC" association talks that interoperability requires more advantageous severe cooperation between distinctive jurisdictions and that may additionally also start with distinctive legacy systems. They should bear in mind that valuable banks are at the moment engaged on wide range of interoperability designs, and these may still no longer be taken as a right. additional scoping of chances has to be undertaken through relevant banks to look which form of arrangement makes feel from the point of view of expertise, economics and governance. they would also need to keep in mind the necessary sort of pass-border cooperation to gauge what's political feasible.
searching beyond the latest Design thinking
The design choices that valuable banks make on CBDC may still be based upon the wonderful policy and regulatory objectives of that principal financial institution. As prior to now mentioned, using CBDC for cross-border payments will stumble upon preexisting fiscal rules spread across the globe, however the CBDC design choices of primary banks should no longer act as a barrier or complicate go border payments. As valuable banks construct a CBDC they will possible come across a whole lot of challenges, now not least of which is the way to be sure that this new technology is enhancing, and never undermining, compliance regimes among countries.
In a latest record through the BIS Innovation Hub on building a multi-CBDC platform for international funds , it highlighted 5 distinctive phases where every part can be set as agile experiments in a secure and controlled atmosphere with specified consideration for technological, policy, prison and company necessities. each part within the roadmap is highlighted by means of the BIS to lead to incremental learnings that can lead to contributions to the evolution of CBDC design, from prototype to pilot, to minimal workable product (MVP) and, ideally, a production-in a position network. For any imperative bank looking for to endure a CBDC assignment which has interoperability in mind, may still formulate a road map which closely mirrors the one highlighted via the BIS Innovation Hub as it offers an outstanding starting base for research and building during this house.
(figure 5 - roadmap to enhancing go-border payments, G20 Stage 2 document)
there's scorching debate on blockchain adoption for CBDC design. qualities of blockchain are in my view suitable for requirements of CBDC design however further work has to be accomplished by way of principal banks and institutions to emphasize test the applicability of this new expertise. they have witnessed many primary banks closing undecided whether their CBDC should be in keeping with a DLT architecture or building a non-DLT, centrally managed infrastructure even though there was a number of studies and concepts developed by way of the BIS Innovation Hub (Inthanon-LionRock mBridge) and Visa with the usual funds Channel (UPC).
despite the fact, the present condition is that there are not any imperative banks which have applied a blockchain primarily based CBDC. there are many challenges that need to be navigated if they wish to see a primary banks the use of such expertise, which comprises examining efficiency, scalability, pass-chain interoperability and usage eventualities. different concerns that deserve to be further analyzed are “interoperability between current and new infrastructures, the entry to and handle of important financial institution money, the big difference between wholesale and retail CBDC, and the role of deepest business actors” (BIS record, 2021) .
it's my view that move-border CBDC can offer transformational advantages both for retail and wholesale banking. I accept as true with in the close future they will see CBDCs replacing present pass- border funds, that are renown for being enormously gradual, high priced, and sophisticated, and should enhance effectivity and discounts in business and enterprise techniques. They should predict to see further stories undertaken via central banks and institutions in exploring the design of an interoperable device to make pass-border payments quicker, more cost-effective, more transparent and greater attainable to all, whereas holding security and security.
And if this does contain blockchain know-how with web three.0 in mind, should still the attributes of interoperability incorporate digital currencies on a decentralized public network? for my part they may and they will see extra traction because the technology evolves, with extra schooling on this subject matter to crucial bankers.
As we've witnessed during the past, valuable banks had been capable of grant vigour to a further to finalize transactions in its currency, or a new centralized middleman would have had to be created. despite the fact, nowadays in the course of the innovation the usage of blockchain know-how they are able to envisage a higher answer, one which works with the grain of the present economic gadget, which can be argued is inherently decentralized already. throughout the aggregate of programmable funds (smart contracts), cryptographically cozy APIs at the critical financial institution layer, aided by ‘atomic swap’ protocols, and coordinated with the aid of a battle confirmed blockchain platform, this can also just be future reply to how CBDCs could be rolled out.
what's a crucial financial institution digital currency? Is the federal reserve moving in opposition t a digital dollar? https://www.federalreserve.gov/faqs/what-is-a-vital-bank-digital-currency.htm 
Cryptocurrency vs. central financial institution money: does the way forward for digital foreign money lie with imperative banks? https://www.instinct.com/cryptocurrency-vs-central-bank-cash-does-the-future-of-digital-forex-lie-with-vital-banks/ 
Roadmap for enhancing cross-border payments: first consolidated progress report, FSB, https://www.fsb.org/2021/10/g20-roadmap-for-improving-pass-border-payments-first-consolidated-growth-document/ 
Digital currencies are chopping across borders. here's how regulators can capture up, WEF, https://www.weforum.org/agenda/2021/12/cbdc-stablecoin-digital-foreign money-rules/ 
CBDC and interoperability: your questions answered, R3, https://www.r3.com/weblog/cbdc-and-interoperability-your-questions-answered/ 
Blockchain options for vital bank digital forex (CBDC), Consensys, https://consensys.web/options/funds-and-funds/cbdc/ 
What does interoperability suggest for CBDCs? DigFin, https://www.digfingroup.com/what-does-interoperability/ 
Making digital currency interoperable, Visa, https://us of a.visa.com/visa-all over/blog/bdp/2021/09/29/making-digital-foreign money-1632954547520.html 
enhancing cross-border funds, Stage 2 record to the G20. Committee on funds and Market Infrastructures (July 2020). financial institution for international Settlements. https://www.bis.org/cpmi/publ/d193.pdf 
Blockchain and vital financial institution digital forex Tao Zhang & Zhigang Huang, https://www.sciencedirect.com/science/article/pii/S2405959521001399 
building a multi-CBDC platform for foreign funds, BIS Innovation Hub, https://www.bis.org/publ/othp40.pdf 
Interoperability between payment methods across borders, BIS bulletin No. 49, https://www.bis.org/publ/bisbull49.pdf 
HSBC and IBM successfully Design and verify Interoperable Multi-Ledger vital bank Digital forex, Securities and overseas exchange contract means, https://newsroom.ibm.com/2021-12-sixteen-HSBC-And-IBM-correctly-Design-And-check-Interoperable-Multi-Ledger-vital-bank-Digital-currency,-Securities-And-foreign-alternate-settlement-skill 
critical financial institution digital currencies: foundational principles and core aspects, BIS, https://www.bis.org/publ/othp33.pdf 
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