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Roger King is right ("Safeguarding quality could soon become a very risky business", 21 July) to urge caution before the sector grabs the notion in the recent White Paper that some institutions might receive less frequent or intensive reviews on the basis of assessed risk.

In the consultation document that followed the White Paper, the Higher Education Funding Council for England has accepted that there is no "formulaic way" to distinguish between institutions on grounds of quality. This echoes the Browne Review committee's acknowledgement that "there is no measure (of quality) that could function effectively across the whole range of institutions and courses" (unfortunately, it didn't prevent them from recommending a bigger role for such information to guide student choices).

As the supplier of what is basically a "non-market" product, higher education has not benefited greatly from practices introduced from the corporate sector since the mid-1980s. But we can learn from recent corporate governance failures in the City and elsewhere that, as King shows, risk-based regulation actually increases rather than diminishes risks.

Risk management is predicated on the assumption that one can identify and mitigate the risks associated with the business one is in. But as recent events show, the risks that matter are precisely those that cannot be foreseen. Devoting resources to the compilation and refinement of risk registers, risk committees and similar tools is therefore largely a waste of resources that would be better invested in the core business.

Roger Brown, Professor of higher education policy, Liverpool Hope University, and former chief executive, Higher Education Quality Council