Ramsay, Iain (2007) Comparative Consumer Bankruptcy. Illinois Law Review, 2007 (1). pp. 241-274. (Access to this publication is currently restricted. You may be able to access a copy if URLs are provided) (KAR id:1647)
PDF
Language: English Restricted to Repository staff only |
|
|
|
Official URL: http://home.law.uiuc.edu/lrev/publications/2000s/2... |
Abstract
This article discusses comparative consumer bankruptcy in the context of the international spread of consumer credit capitalism and its accompanying social cost, overindebtedness. The article outlines the contours of regulation of credit markets and overindebtedness within Europe, the influence of the U.S. idea of the “fresh start” on recent changes in European debt-adjustment laws and continuing contrasts with the U.S. approach to bankruptcy. As consumer debt increases in Europe and elsewhere, these differences between continental European and North American approaches to bankruptcy might be explained by the path-dependence of legal institutions, cultural differences, or the political influence of interest groups. The article is skeptical about cultural explanations of difference and suggests the value of an analysis that is sensitive to political economy and history.It also argues that future comparative research should focus on overindebtedness rather than bankruptcy.
Item Type: | Article |
---|---|
Subjects: | K Law |
Divisions: | Divisions > Division for the Study of Law, Society and Social Justice > Kent Law School |
Depositing User: | A. Davies |
Date Deposited: | 19 Dec 2007 19:06 UTC |
Last Modified: | 16 Nov 2021 09:40 UTC |
Resource URI: | https://kar.kent.ac.uk/id/eprint/1647 (The current URI for this page, for reference purposes) |
- Export to:
- RefWorks
- EPrints3 XML
- BibTeX
- CSV
- Depositors only (login required):