SOVEREIGN INSOLVENCY PROCEDURES – A COMPARATIVE LOOK AT SELECTED PROPOSALS
比较了六项主权破产程序的政策提案，指出改进方向，为达成政治共识提供基础，适合关注主权债务重组机制的研究者。
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.