Consumer bankruptcy and over-indebtedness is an emerging field throughout the world. This book provides a comparative appraisal of global developments in this area. It combines theoretical and empirical studies of bankruptcy regimes and consumer credit in civilian and common law jurisdictions as well as exploring current reform trends. The book should be of interest to academics, policymakers and law reformers as well as to practitioners.

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Since 1979 the world has witnessed a remarkable cycle of individual bankruptcy law reform. Changes in capitalist economies, financial crises and political interest groups all contributed to this cycle of reform. Differences exist between European systems in terms of access criteria, institutional frameworks, financing and discharge conditions. What explains these differences within Europe and those between Europe and the US? This book draws on insights from historical institutionalism to illustrate the role of timing, path dependency and unintended consequences in the development of...