Banks do not always include potential barriers to the cross-border flow of liquidity in their stress tests, even though these can be particularly prevalent in crisis situations. In the face of potential barriers to the cross-border flow of liquidity and collateral, the BSC regards running stress tests at both the group and the entity level and accounting for these potential barriers in liquidity stress tests and contingency funding plans (CFPs) as improvements on current practice. Secretiveness on behalf of the banks is another problem that impedes a comparison of stress tests and their outcomes. The ECB proposes concerted stress tests for Eurozone banks. Proper information policy is not encouraged, though. The ECB recognizes the fact that early publication of banks' liquidity problems may aggravate the survival chances of a bank while paying only lip-service to shareholders information rights.

Banks are reluctant to disclose the results of their liquidity stress tests (apart from to supervisors, rating agencies and some key counterparties) because the results cannot be interpreted without a detailed understanding of the scenarios and the considerations underlying them. The results are therefore not comparable across banks. In addition, public disclosure could have negative repercussions on the liquidity situation of some banks under certain circumstances. While more disclosure, in particular on banks’ liquidity risk management, is generally to be encouraged, the BSC considers that, in the case of liquidity stress test results, the detrimental effects of mandatory public disclosure are likely to outweigh the benefits. Nevertheless, a majority of banks also regard public disclosure in this area as a tool for enhancing market discipline, subject to certain preconditions. In this respect, concerted rounds of common liquidity stress tests – which are conducted, for example, for supervisory/financial stability purposes without affecting banks’ routine liquidity stress tests for internal purposes – would help to increase the comparability of the output of internal models across banks.

The ECB did not find more encouraging practices concerning contingency fund plans (CFP.) As with stress tests there is no ideal CFP that would be applicable to all banks.