Comparative Consumer Insolvency Regimes
A Canadian Perspective
By (author) Jacob S. Ziegel
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Comparative Consumer Insolvency Regimes by Jacob S. Ziegel
Book DescriptionAll 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.
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Book DetailsISBN: 9781841132723
(234mm x 156mm x 16mm)
Imprint: Hart Publishing
Publisher: Bloomsbury Publishing PLC
Publish Date: 22-Sep-2003
Country of Publication: United Kingdom
Books By Author Jacob S. Ziegel
New Developments in International Commercial and Consumer Law, Hardback (May 1998)
This volume contains original and practical papers on new developments in International Commercial and Consumer Law.
Current Developments in International and Comparative Corporate Insolvency Law, Hardback (November 1994)» View all books by Jacob S. Ziegel
Recent years have witnessed an unprecedented growth in insolvency law. This collection of essays covers recent developments in a number of jurisdictions and examines developments of the leading corporate insolvency specialists in the USA, UK, Australia, Japan and Canada.
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Author Biography - Jacob S. Ziegel
Jacob S. Ziegel is Professor of Law Emeritus in the Faculty of Law at the University of Toronto.
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