Jacob Ziegel

Comparative Consumer Insolvency Regimes (eBook, PDF)

A Canadian Perspective

• Format: PDF

Produktbeschreibung

All modern legal systems with advanced economies must address the question of how to respond to the needs of insolvent consumers whose burden of debt greatly exceeds their capacity to repay within a reasonable time frame. This study surveys comparatively the insolvency regimes currently in place or likely to be adopted in the foreseeable future in Canada,the United States, Australia, England and Wales, Scotland, Scandinavia and a representative group of Western countries on the continent of Europe.

Modern legal systems have two basic alternatives in providing relief for over-committed consumers. The first, which involves restricting the enforcement of individual creditor remedies is a method with which this study is not concerned. Where the consumer is seriously insolvent and owes money to many creditors, a different approach is required -- a collective solution to debtor's problems - and this, the solution provided by modern insolvency systems, is the focus of this study.

Produktdetails

• Verlag: Bloomsbury UK
• Seitenzahl: 212
• Erscheinungstermin: 22. September 2003
• Englisch
• ISBN-13: 9781847311399
• Artikelnr.: 52923383

Autorenporträt

Jacob S. Ziegel is Professor of Law Emeritus in the Faculty of Law at the University of Toronto.

Inhaltsangabe

Part A Introduction 1 Purpose of Study Part B Country Surveys 11 2 Canada 3
United States 4 Australia 5 England and Wales 6 Scotland 7 Scandinavia and
Continental Countries of Western Europe Part C Assessing the Various
Insolvency Regimes and Suggestions for Changes 8 Assessment and Suggestions
for Changes