The Evolution of Risk Accounting
Jamie Dimon vs. Basel III: The Impact of Operational Risk Capital Requirements on Banking
The Basel III framework, introduced in the wake of the 2008 financial crisis, was designed to strengthen the regulation, supervision, and risk management of banks.
One of its key components is the operational risk capital requirement, which mandates that banks hold sufficient capital to cover potential losses arising from operational risks. However, this aspect of Basel III has not been without controversy.
One of its most vocal critics is Jamie Dimon, the CEO of JPMorgan Chase, who has raised significant concerns about the impact of these requirements on the banking industry.
In this article, we’ll explore Dimon’s criticisms, the rationale behind the Basel III operational risk capital requirements, and how risk accounting could offer a more effective solution that addresses the concerns of both regulators and industry leaders.

JPMC's Jamie Dimon's Views on Risk Regulations
Jamie Dimon, the CEO of JPMorgan Chase, has expressed concerns about the regulatory focus on operational and non-financial risks, emphasizing that excessive regulation in these areas could stifle innovation and burden financial institutions with unnecessary costs.
He argues that while managing operational risks, such as cybersecurity and compliance, is critical, the regulatory approach should be balanced and not overly prescriptive. Dimon believes that regulations should be designed to enhance the resilience of the financial system without impeding the ability of banks to serve their customers effectively.
He also highlights the importance of allowing financial institutions the flexibility to develop their own risk management frameworks tailored to their specific operations rather than imposing a one-size-fits-all regulatory standard.
Dimon stresses that regulators should focus on outcomes rather than processes, encouraging banks to take proactive measures in managing risks without being bogged down by overly detailed rules.
Dimon advocates for a regulatory environment that promotes both financial stability and innovation, ensuring that banks can continue to play a vital role in supporting the broader economy.
The Rationale Behind Basel III’s Operational Risk Capital Requirements
The operational risk capital requirements under Basel III were introduced to ensure that banks have enough capital to absorb losses resulting from failures in internal processes, systems, people, or external events. The idea is that by holding sufficient capital, banks can protect themselves—and the broader financial system—from the potential fallout of operational risks.
Basel III uses a standardized approach to calculate these capital requirements, which is largely based on the Business Indicator—a proxy for operational risk derived from certain financial statement items, as we discussed in a previous article. This approach was intended to simplify the calculation of operational risk capital and make it easier for banks to comply with regulatory requirements.
The rationale behind these requirements is sound: by ensuring that banks are adequately capitalized, regulators aim to prevent the types of systemic crises that nearly brought down the global financial system in 2008. However, the implementation of these requirements has not been without its challenges, leading to significant pushback from industry leaders like Jamie Dimon.
Jamie Dimon’s Critique
Jamie Dimon has been one of the most outspoken critics of Basel III’s operational risk capital requirements. In a 2023 interview with CNBC, Dimon expressed his frustration with the regulatory framework, arguing that it imposes excessive and unnecessary burdens on banks. His main points of criticism include:
- Impact on Lending and Economic Growth: Dimon argues that the capital requirements under Basel III are too high, which forces banks to hold large amounts of capital that could otherwise be used for lending. This, in turn, can restrict the availability of credit to consumers and businesses, potentially slowing economic growth. As Dimon put it, “If they want to put all mortgages and small business loans out of the banking system, so be it, but they should tell that to the American public. It will have a real effect on consumers.”
- Lack of Calibration and Flexibility: Dimon has also criticized the lack of calibration in the operational risk capital models, arguing that they are too rigid and do not accurately reflect the actual risk profile of individual banks. This one-size-fits-all approach, according to Dimon, fails to account for the unique characteristics and risk exposures of different institutions.
- Potential Unintended Consequences: Dimon warns that the Basel III requirements could lead to unintended consequences, such as pushing certain financial activities outside of the regulated banking sector and into the shadow banking system, where they are subject to less oversight. This could increase the overall risk in the financial system, rather than reducing it.
Dimon’s critiques resonate with a broader concern within the banking industry that the regulatory approach to operational risk capital is too prescriptive and may stifle innovation and growth.
The Broader Industry Perspective
Dimon’s concerns are not isolated. Many within the banking industry share his view that the Basel III operational risk capital requirements are overly burdensome and do not accurately reflect the risks faced by individual institutions. There is a growing sense that the current approach to regulating operational risk may need to be revisited to strike a better balance between ensuring financial stability and supporting economic growth.
This tension between regulation and industry needs is not new. It highlights the ongoing challenge of designing regulatory frameworks that are robust enough to prevent crises but flexible enough to accommodate the diverse needs of financial institutions.
Risk Accounting: A Path Forward?
The criticisms of Basel III’s operational risk capital requirements underscore the need for a more nuanced and adaptable approach to managing operational risks. Risk accounting offers a potential solution that could address the concerns raised by Dimon and others in the industry.
- Risk Sensitivity and Flexibility: Unlike the standardized approach used in Basel III, risk accounting allows for a more tailored assessment of a bank’s operational risk profile. By quantifying risks based on current exposures and potential future events, risk accounting provides a clearer picture of the true level of risk. This risk-sensitive approach can help ensure that capital requirements are more accurately aligned with the actual risks faced by the institution.
- Optimized Capital Allocation: Risk accounting can also help optimize the allocation of capital by providing a more precise measure of risk. This means that banks can hold the right amount of capital—enough to cover potential losses, but not so much that it stifles lending and economic growth. This balance is crucial for supporting both financial stability and economic expansion.
- Enhanced Transparency and Comparability: By integrating risk measures into financial statements, risk accounting enhances transparency and allows for better comparability across institutions. This makes it easier for regulators to assess the overall risk profile of the financial system and for banks to benchmark themselves against their peers.
- Support for Innovation: Risk accounting’s adaptability makes it well-suited to support innovation within the financial industry. By providing a flexible framework for assessing and managing risks, risk accounting can help banks navigate new and emerging risks, ensuring that they remain competitive and resilient in a rapidly changing environment.
A Brief Introduction to Risk Accounting
Risk accounting is an innovative approach that combines traditional accounting practices with advanced risk management techniques. It involves identifying, quantifying, and aggregating risks across an organization and integrating these risk measures into financial statements. This provides a more comprehensive and transparent view of a company’s financial health, enabling better decision-making and more effective risk management.
Conclusion
The debate over Basel III’s operational risk capital requirements highlights the complex interplay between regulation and industry needs. While the goal of these requirements is to ensure financial stability, their implementation has raised concerns about their impact on lending, economic growth, and the overall flexibility of the banking system. Risk accounting offers a promising alternative that could address these concerns by providing a more tailored, transparent, and adaptable approach to managing operational risks.
As we conclude this series, it’s clear that risk accounting represents a critical innovation in the field of risk management. For those interested in learning more about risk accounting, additional resources are available to deepen your understanding of this essential approach.
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