Banks in the European Union subject to International Financial Reporting Standards (IFRS) had to implement IFRS 9 as of 1 January 2018. One of the main concerns with the implementation of IFRS 9 is that it would cause a sudden increase in Expected Credit Loss (ECL) estimates, which would cause an abrupt and significant decline in Common Equity Tier 1 (CET1) regulatory capital ratios for many banks in the European Union.