This book provides a detailed analysis and critical assessment of the EU and US resolution regimes for banks and financial institutions on a comparative basis.
The book analyses the EU legal framework under the Bank Recovery and Resolution Directive, and considers the challenges in national implementation through the two largest economies within the EU, Germany and the UK. The very influential laws of the US, (Securities Investor Protection Act 1970, and the Wall Street Reform and Consumer Protection Act: Dodd-Franck) are used as a comparative reference point.
Through analysis of the...