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The Impact of Legislation on Credit Risk—Comparative Evidence From the United States, the United Kingdom and Germany, Philipp Schmieder, Christian Schmieder

Abstract
This study investigates the link between bankruptcy and security legislation and potential credit losses faced by banks based on a cross-country study for the United States (US), the United Kingdom (UK) and Germany. Focusing on corporate credit, we find that legislation produces the highest credit risk in the US, followed by Germany, while UK law is found to be most favorable for banks. US banks gains from the higher number of informal restructurings (without losses) but lose from the low level of recovery in formal proceedings. German banks demand more credit risk mitigants than UK and US banks do, but still recover less than do UK banks. To be at par with UK banks, US banks would have to recover more than twice as much in formal proceedings, while German proceedings would have to be shortened by about one half
Table Of Contents
Cover Page; Title Page; Copyright Page; Contents; I. Introduction; II. Legal Perspective to Credit Risk and Hypotheses; A. General Aspects and Notions; B. Credit Risk and Bankruptcy Legislation; 1. Stylized Default Process; C. Credit Risk and Security Interests; III. Economic Perspective to Credit Risk; A. Probability of Default Modeling; 1. Determinants of Probability of Default Modeling; B. Loss-Given Default Modeling; 2. Determinants of Loss-Given Default Modeling; IV. Comparison of the Bankruptcy and Secured Transactions Legislation of Germany, the United Kingdom, and the United States
Language
eng
Literary Form
non fiction
Note
Description based upon print version of record
Physical Description
1 online resource (91 p.)
Specific Material Designation
remote
Form Of Item
online
Isbn
9786613882264

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