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The US and English models for financial restructurings of companies in financial difficulties are fundamentally different. The first edition of this work was written in the wave of restructurings precipitated by the credit crisis which brought into the spotlight arguments that the principles behind the US chapter 11 regime ought to be imported into a UK statutory scheme. Since then, the American Bankruptcy Institute Commission to Study Reform of Chapter 11 has reported, and the European Commission has issued a recommendation on a new approach to business failure and insolvency. Creditors increasingly have security over the debtor's assets in the US, whilst the very nature of the finance market is changing in the UK. Across much of Europe reform of restructuring procedures is underway or under consideration. This edition is written against a backdrop of reflection and revision.
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