基本説明
A comparative appraisal of bankruptcy regimes and consumer credit in civilian and common law jurisdictions.
Full Description
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 is one of the first book length publications focusing on comparative consumer bankruptcy and over-indebtedness. 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 will be of interest to academics, policymakers and law reformers as well as to practitioners.
Contents
Introduction
JOHANNA NIEMI-KIESILÄINEN, IAIN RAMSAY, WILLIAM C WHITFORD
I: Theoretical Perspectives on Consumer Bankruptcy
1. Consumer Credit Society and Consumer Bankruptcy: Reflections on Credit Cards and Bankruptcy in the Informational Economy
IAIN RAMSAY
2. Collective or Individual? Constructions of Debtors and Creditors in Consumer Bankruptcy
JOHANNA NIEMI-KIESILÄINEN
3. Personal Bankruptcy Law: A Behavioural Perspective
SAUL SCHWARTZ
II: Consumer Over-indebtedness in Countries Without Bankruptcy
4. Consumer Bankruptcy and Over-indebtedness in Brazil
JOSÉ REINALDO DELIMA LOPES
5. Development of Consumer Credit in China and Concerns about the Underlying Legal Infrastructure
XIAN-CHU ZHANG
6. Searching for an Over-indebtedness Regulatory System for Portugal and the European Union
MARIA MANUEL LEIT MAO MARQUES AND CATARINA FRADE
III: New Consumer Bankruptcy Systems
7. 'Thou shalt pay thy debts' Personal Bankruptcy Law and Inclusive Contract Law
UDO REIFNER
8. The Political Economy of Personal Bankruptcy in Israel
RAFAEL EFRAT
9. Current Trends in Consumer Insolvency in Hong Kong
CHARLES D BOOTH
IV: Changes in and Evaluations of Mature Consumer Bankruptcy Regimes
10. Bankruptcy in Transition: The Case of England and Wales—The Neo-Liberal Cuckoo in the European Bankruptcy Nest?
IAIN RAMSAY
11. Developments in Consumer Bankruptcy in Australia
ROSALIND MASON AND JOHN DUNS
12. New Zealand Bankruptcy Law Reform: The New Role of the Official Assignee and the Prospects for a No-Asset Regime
THOMAS GW TELFER
13. Who Uses Chapter 13?
TERESA A SULLIVAN, ELIZABETH WARREN, JAY LAWRENCE WESTBROOK
14. Generosity Versus Accessibility: Bankruptcy, Consumer Credit and Health Care Finance in the US
MELISSA B JACOBY
V: Debtor Education and Debtor Counselling
15. Can Voluntary Debt Settlement and Consumer Bankruptcy Coexist? The Development of Dutch Insolvency Law
NICK HULS, NADJA JUNGMANN, BERT NIEMEIJER
16. Debtor Education in Bankruptcy: The Perspective of Interest Analysis
JEAN BRAUCHER
17. Establishing Financial Literacy Programmes for Consumer Debtors: Complex Issues on the Platter
KAREN GROSS
