In the United States it takes 150 highly trained bank examiners. In Ireland it takes one minister and a small group of number crunchers from PricewaterhouseCoopers (PWC).

In the US every potential bank investor, current shareholder, bondholder, depositor, hey even taxpayer, can go to the following webpage (www.federalreserve.gov-/newsevents/) and click on a 38-page document which lays bare the capital adequacy of America's entire financial system. The document includes a summary of the current capital position of the 19 largest banks in the country. Nothing is blanked out or marked "commercially sensitive", unlike the PWC report on Anglo Irish released a few months ago.

The stress testing of banks in the US is not to everyone's taste. In fact its critics believe it's an entirely cosmetic exercise which is only delaying the inevitable: the US economy is sliding towards a Japanese-style 'lost decade' where zombie banks muddle through year after year holding back an overall national economic recovery.

Others demur and believe that with a recovery under way in the US, however anaemic, US banks could actually end up over-capitalised at the end of the stress-test process. Either way the stress-testing exercise, led by US Treasury secretary Tim Geithner, at least has a commendable ambition – to ease market uncertainty about the ability of the country's banks to weather the next phase of the 'great recession'.

Geithner's ambition is matched by his methods. The stress tests of the 19 banks are in-depth, uniform and most remarkably the results are publicised. Economists such as Josepth Stiglitz aren't happy about the unemployment assumptions used to stress test the banks, but investors aren't listening to him. The Standard & Poor's 500 financials index reached its highest level in four months on 6 May as the stress test results leaked out.

Contrast the US approach to what we are doing here. Yes the scale is different of course, but the problem is broadly the same. The US and Ireland both have banks which are believed to be hugely under capitalised. Some of the banks may even be insolvent.

Investors are nervous about the latter, but also the former.

Financial results when released are inevitably months out of date and are prepared by the banks themselves, who tend to like to walk on the sunny side of the street when it comes to assessing potential losses on their loans.

The Minister for Finance Brian Lenihan touched upon the subject in a radio interview last week when he said he was doing his own stress tests of the main banks, with Bank of Ireland and AIB already tested and assessed. The conclusion is Bank of Ireland needs €3.5bn, AIB needs €5bn.

For the Irish taxpayer this means a cumulative and soul-destroying bill of €7bn, with the rest of the money coming from AIB's planned asset sales. The rationale for the €5bn figure was provided by the Government in a short four-page statement released on 20 April.

The statement says the €5bn is needed after "due diligence'' was done and after AIB's books were exposed to a "range of stress-test scenarios''. And that's that.

The various stress scenarios used have not been released, the outcomes not published and crucially the macro-economic assumptions behind the stress tests have not been disclosed.

Clearly the core tier 1 capital of AIB is inadequate, the same presumably goes for Anglo Irish Bank, and Irish Nationwide's capital adequacy is already below thresholds set by the Financial Regulator.

But the precise reasons for these shortfalls and the precise scale of these shortfalls are not to be revealed to shareholders in the case of AIB, to members in the case of Irish Nationwide and to the taxpayer in the case of Anglo Irish Bank.

One has to harbour the suspicion that the government's reluctance to publish stress-test results, or even the criterion used in such exercises, is because the full scale of capital depletion at the main banks would be revealed to equity markets, the taxpayer and crucially to the bond market.

Instead of publishing stress-test results the government wants to stress test the patience of the markets by altering the rules on capital adequacy. It is now suggested for example that Anglo Irish no longer needs to have the core tier 1 ratios of old, seeing as it's now a nationalised entity. This may be true, but the government still needs to fund the bank and counter parties to Anglo might not be so prepared to look the other way in the long term.

In the US Geithner is hoping that publishing the results of stress tests will help to entice private shareholders to recapitalise the US banks. He also hopes that publication will assuage US taxpayers about how deep the hole that needs to be filled, possibly by them, really is.

He may fail in both objectives, but the aspirations are laudable.

Here the banks and the government, bizarrely, hope that investors will invest in Irish bank shares by blocking all access to the key information they need to make a rational investment decision: their capital levels. The government's chief economic advisor Dr Alan Ahearne recently wrote that banks here should not be nationalised, but instead should stay privately owned and should be subject to "market discipline''.

Changing the rules on the levels of capital the banks need to have doesn't seem to be consistent with that wish.

Major international investors have told the government in recent weeks that until the scale of the loan losses and knock-on capital effects are brought out into the open, investment in Irish bank shares will remain seriously limited.

The less private money washing around means the lower the share prices of the Irish banks, meaning the government will be left having to take even larger stakes in the individual institutions later this year.

In that context the reluctance to put hard numbers, post stress-testing, into the public domain is perplexing.

Stress-testing in private in government buildings does not constitute bringing things out into the open and is not working.