MADRID | March 13, 2015 | By JP Marín Arrese | The quantitative test conducted under the Dodd-Frank Act showed a comfortable capital cushion for all eligible banks. Yet both Santander and Deustche Bank subsidiaries blatantly failed the qualitative review undertaken by the Fed under the Comprehensive Capital Analysis and Review (CCAR). In short, the banking supervisor considered their capital plans and risk management to be utterly inconsistent. It has delivered a damaging blow that should prompt swift action to redress such an appalling outcome. Santander has already announced a major overhaul in its US banking arm, but the Group as a whole badly needs to address its failures.