This is exactly what I do for my day job, and I agree with you. I work adjacent to the investment industry in Europe (my fintech produces regulatory disclosure materials). If you market investment products (generally called PRIIPs, though certain types of products are excluded) here, you are required to produce an investor information document that includes standardized information, including figures that are computed according to defined formulae. One of these is the Summary Risk Indicator (SRI), which purports to reflect the product’s apparent risk, on a scale from 1 (low) to 7 (high). A large contributor to this figure is the historical volatility of the product (or a substitute equivalent product or index if insufficient history is available).
Risk, in a generalized sense, is basically impossible to state in an objective, quantified way. If it were possible to concretely measure and predict risk, then nobody would lose money, right? It seems to me, therefore, that a narrower view of risk is implied by its conflation with volatility. Rather than a broad prediction of how well the product will or won’t do over some arbitrarily long horizon, you can consider volatility in order to estimate the probability of the product being up or down at any particular point when you need to take your money out. If the product historically shows slow but steady growth, the risk of absorbing a loss at a given point is lower. But if it’s highly volatile, and you have a specific exit date, the chances are higher that the product will be down on that day.
This is not really “risk” in the way normal people think about it, of course, exactly as you say. But volatility can be measured, and our regulators want the investment companies to avoid squishy non-objective marketing-speak, so this is what we end up with, the least-bad of a range of not-good options. Even though it flies in the face of the legally mandated “past results are not a guarantee of future performance” language that appears in every prospectus, the PRIIP KID nevertheless uses past results to present what appears to the lay investor to be a prediction of future performance.
For those who are curious, the complex process by which the SRI and associated “performance scenarios” (i.e. “this is how the product might do over five years in a good market, or a down market, or a crisis market…”) are derived can be seen in this PDF document. It’s 35 pages of technical gobbledegook, so if you’re not in the industry, feel free to skim through just to get a flavor for the complexity imposed by the regulators. Starting on page 18, you can see the decision flows whereby the amount of history to be considered is determined, and then the brain-melting mathematics start a couple of pages later. It’s a whole lot of mandatory precision which is intended to lend an air of authority to something which is inherently imprecise and unknowable, but that’s how it’s done.
Obligatory caveat: This is of course specifically relevant to European regulation, but the mindset behind it is common in the broader industry.
So, yeah, I agree with what you’re saying, but maybe the above inside-baseball perspective will help you give your son some context and explain why things are the way they are.