Banking

Consumer Bankruptcy Regimes And Credit Default In The US And Europe: A Comparative Study

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Executive Summary

This CEPS Working Document explains the consumer bankruptcy procedures in the US and the five largest European countries: the UK, Germany, France and Spain, plus Italy (which has no special legal provisions for consumer insolvency). All these countries have quite different approaches; the paper therefore presents a short overview of the insolvency procedures and trends in bankruptcy numbers for each country. Consumer insolvency is a topic that has gained much prominence in the context of the financial crisis on both sides of the Atlantic. In countries such as the US and the UK, bankruptcy filings have always been more frequent, but their numbers have been soaring in recent years.

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