SOVEREIGN INSOLVENCY PROCEDURES – A COMPARATIVE LOOK AT SELECTED PROPOSALS

Abstract.  The most practicable short-term approaches for sovereign debt restructuring would include a code of conduct (voluntary approach) and collective action clauses (contractual approach). In the medium term, a sovereign insolvency procedure (statutory approach) may have an important role to play because it would be a comprehensive instrument designed to coordinate different creditor groups prior to and during a debt crisis. This paper provides a survey of six comprehensive policy proposals for a sovereign bankruptcy procedure. It points to approaches that could improve existing proposals and creates a basis for new proposals which could prove conducive to reaching political consensus.