The EBA has told EU banks that they must raise a total of €114.69 ($153.31 billion) in quality capital to meet the 9% core capital to liabilities ratios stipulated in October. But that's worrisome for European Central Bank President Mario Draghi, who says leaders must ensure that banks don't raise that capital level by simply deciding not to lend anymore.

When the first round of stress tests came out in July, we weren't so sure we could trust the EBA's tests or fundraising recommendations. So we conducted our own round of stress tests by comparing total bank exposure in a specific country to common equity. Our guesses for which banks were under the most stress appear to have been right on the mark, with the failure of Dexia and now the weakness of Commerzbank.