An outside view on the ECB’s
Comprehensive Assessment
Ulf Lewrick, CGFS Secretariat, Monetary and Economic Department
11 November 2014
The views expressed are those of the author and not necessarily the views of the BIS.
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Main concerns ex ante
 No multilateral ex-ante backstop arrangement
 Too lenient stress test design?
 Inconsistency of data across banks?
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Headline results & taking a second look
 Net capital shortfall appears small & mostly concentrated in
smaller banks
 Results based on fully loaded CRR rules are not as favourable
 AQR impact raises some questions
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Austrian banks – some observations
 Transitional adjustments
 Sovereign exposures
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