This book provides a detailed analysis and critical assessment of the EU and US resolution regimes for banks and financial institutions on a comparative basis. The book analyses the EU legal framework under the Bank Recovery and Resolution Directive, and considers the challenges in national implementation through the two largest ecomies within the EU, Germany and the UK. The very influential laws of the US, (Securities Investor Protection Act 1970, and the Wall Street Reform and Consumer Protection Act: Dodd-Franck) are used as a comparative reference point. Through analysis of the new EU framework and of the more mature system in the US, the book considers whether and to what extent the EU framework and national regimes contribute to ensuring resolvability of financial institutions, how their efficacy may be increased with a view, in particular, to the resolution of cross border groups, and what the future may hold, especially in respect of a single European resolution authority.
Dr Michael Schillig is Reader in International Commercial and Financial Law at The Dickson Poon School of Law, King's College London. Michael read law at the University of Erlangen-Nuremberg, obtained his LL.M. from King's College London and his Dr.iur. from Humboldt University Berlin. Michael's research interests lie broadly in the areas of transnational, European and comparative commercial law with particular emphasis on contract, company and corporate insolvency law. He has published widely in these areas.