Header

UZH-Logo

Maintenance Infos

A Comparison of US, UK, and German Insolvency Codes


Franks, Julian; Nyborg, Kjell G; Torous, Walter (1996). A Comparison of US, UK, and German Insolvency Codes. Financial Management, 25(3):86-101.

Abstract

This paper describes three insolvency codes, those of the United Kingdom (UK), Germany, and the United States (US) and compares their efficiency against a number of benchmarks. These codes have been chosen because they cover a broad spectrum of debtor- and creditor-oriented insolvency procedures. The paper also compares the plans of distressed firms' reorganizations both within and outside the formal bankruptcy process, including the size of write downs and creditors' claims and the deviations from absolute priority which have accrued both to equityholders and different classes of creditors. Some evidence of the costs of bankruptcy is also provided for each country.

Abstract

This paper describes three insolvency codes, those of the United Kingdom (UK), Germany, and the United States (US) and compares their efficiency against a number of benchmarks. These codes have been chosen because they cover a broad spectrum of debtor- and creditor-oriented insolvency procedures. The paper also compares the plans of distressed firms' reorganizations both within and outside the formal bankruptcy process, including the size of write downs and creditors' claims and the deviations from absolute priority which have accrued both to equityholders and different classes of creditors. Some evidence of the costs of bankruptcy is also provided for each country.

Statistics

Citations

52 citations in Web of Science®
83 citations in Scopus®
Google Scholar™

Altmetrics

Downloads

1 download since deposited on 21 May 2015
0 downloads since 12 months
Detailed statistics

Additional indexing

Item Type:Journal Article, refereed, original work
Communities & Collections:03 Faculty of Economics > Department of Banking and Finance
Dewey Decimal Classification:330 Economics
Language:English
Date:1996
Deposited On:21 May 2015 10:30
Last Modified:08 Dec 2017 12:59
Publisher:Wiley-Blackwell Publishing, Inc.
ISSN:0046-3892
Additional Information:Special Issue: European Corporate Finance
Publisher DOI:https://doi.org/10.2307/3665810
Related URLs:http://www.jstor.org/stable/3665810
Other Identification Number:merlin-id:11975

Download