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Prospects for reorganisation within european bankruptcy laws

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We present summaries and comparisons of the reorganization opportunities within current bankruptcy codes in the US, the UK, France, and Germany. We discuss the main implications for firms facing financial distress according to the previsions avaible. The focus is on the usefulness of the applicable legal framewoek in ameliorating the difficulties facing a distressed debtor, mainly, asymmetries of information, conflicts of interest, distorted incentives, and ability to obtain financing to remain in business. In spite of some efforts to remedy the situation, continental Europan nations continue to provide mixed opportunities and provisions for resolving the problems facing a viable, liquidity constrained firm. We present some very coarse summary data which support our insights. In the conclusion we discuss some of the different philosophies and policies behind the different codes, and how these views impact the nature of the codes and the availability of reorganization in the different countries

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