The emergence of risk-based capital regulation that is allowing banks to use their internal risk models for regulatory purposes was among the main regulatory developments prior to the financial crisis. During the crisis, it became evident these models underestimated the level of risk. The post-crisis regulatory approach brought a reversal of policy by significantly reducing the scope of risk-based capital regulation and making regulations less risk-sensitive. At first glance, this appears to be a step back toward an antiquated, less sophisticated regulatory regime. This article analyses these two regulatory policy transformations: from less risk-sensitive to risk-based before the crisis and from risk-based to less risk-sensitive subsequently. Its main conclusion is that a mixed regulatory system is superior to either purely non-risk-sensitive or purely risk-based regulation, because a mixed system can help mitigate the negative incentives of both non-risk-sensitive and risk-based regulation.

基于风险的资本监管的出现允许银行将其内部风险模型用于监管目的，这是金融危机之前的主要监管发展之一。在危机期间，很明显，这些模型低估了风险水平。危机后的监管方法通过显着减小基于风险的资本监管的范围并降低监管对风险的敏感性，从而扭转了政策的局面。乍一看，这似乎是朝着过时的，不太复杂的监管制度迈出的一步。本文分析了这两种监管政策转变：从危机之前的风险敏感性降低到基于风险的转变，以及随后的风险基础转变成对风险的敏感性降低。