The concept of banking capital risk-sensitivity revisited

The article studies the foundations of the risk-sensitivity concept of regulatory banking capital. The author states that risk of losses, including unexpected ones covered in accordance with the concept by banking capital cannot be measured with satisfactory accuracy. This is the principal obstacle to the concept implementation. The efficacy of Basel III capital regime with parallel use of risk-sensitive and risk-insensitive approaches is under scrutiny. Rationales are adduced that under this regime risk-sensitive approach has no real value. The study of risk-sensitive approach abilities among macro-prudential tools leads to the conclusion that its efficiency is apparently insufficient. The analysis of the academic study on the issue is carried out. This research recommends to impose risk-sensitive capital requirements if the risk of bank assets can be measured quite accurately. It is shown that the study is based on the implicit assumption of the absence of unexpected losses phenomenon in banking activity. This assumption is unrealistic and makes research in effect objectless. The major inference from the study is that the regulatory capital risk-sensitivity concept is not well-founded and its use for capital adequacy regulation is inadvisable. For micro-prudential purposes the simple leverage deems more expedient. It is capable to ensure for capital regulation the reasonable balance of risk-sensitivity to failure, simplicity and comparability.