Consumer Bankruptcy Regimes in the US and Europe - Further effects and implications of the crisis
(CEPS Working Document No. 318/July 2009 by Maria Gerhardt)
ABSTRACT
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, the number of bankruptcy filings has been soaring in recent years, and is not expected to go down in the near future. In Ireland and Spain, however – two other countries that have been hit hard by the crisis – consumer bankruptcy cases remain very low, and this phenomenon is linked to the
severe insolvency regulation in place in these countries.
This CEPS Working Document explains the consumer bankruptcy procedures in the US and five European countries with quite different approaches: the UK, Ireland, Germany, France and Spain. Since there is no law on consumer insolvency in Italy, the situation in this country is outlined only briefly. When considering current statistics on consumer bankruptcies so far, the first effects of the economic crisis can be observed, so the question arises as to what is yet to come and which bankruptcy procedures are the most appropiate. After a short presentation of each insolvency procedure, the developments in national bankruptcy numbers are traced, highlighting striking developments in the different countries studied here.
See attachment for the report.
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