Publication Type

Journal Article

Version

publishedVersion

Publication Date

12-2025

Abstract

This article seeks to analyze the legal, market, and institutional features needed to become an international hub for debt restructuring. To that end, it examines the strategy adopted by Singapore as well as the market and institutional factors generally found in other leading legal and financial centers such as the United States, the United Kingdom, and Hong Kong. It is argued that in jurisdictions that have traditionally had creditor-oriented insolvency systems, such as Singapore, the United Kingdom, and Hong Kong, one of the primary challenges when enhancing the restructuring framework for debtors is ensuring that the insolvency system remains protective of the interests of the creditors. Otherwise, a reform that seeks to support the real economy may end up doing more harm than good, given that creditors may respond by increasing the cost of debt or restricting the availability of credit, ultimately harming firms' access to finance and the promotion of economic growth. Drawing on a novel insolvency index that measures the attractiveness of reorganization procedures from the perspective of debtors, secured creditors, and general unsecured creditors, this article shows how the United States managed to design an insolvency system that is attractive to both debtors and creditors and how Singapore and the United Kingdom have recently enhanced their restructuring framework for debtors while continuing to be attractive jurisdictions for lenders. Therefore, the experiences of these jurisdictions provide valuable lessons for countries seeking to improve their restructuring frameworks. It will be argued, however, that enhancing a country's insolvency and debt restructuring laws represents only the first step toward becoming a restructuring hub. The sophistication of the judiciary, the development of the restructuring ecosystem, and other external factors, such as the international recognition of reorganization procedures, will also play an essential role in the success of a jurisdiction seeking to become an international hub for debt restructuring.

Discipline

Asian Studies | Business Organizations Law

Research Areas

Corporate, Finance and Securities Law

Publication

American Business Law Journal

Volume

62

Issue

4

First Page

241

Last Page

312

ISSN

0002-7766

Identifier

10.1111/ablj.70004

Publisher

Wiley

Copyright Owner and License

Authors-CC-BY

Creative Commons License

Creative Commons Attribution 3.0 License
This work is licensed under a Creative Commons Attribution 3.0 License.

Additional URL

https://doi.org/10.1111%2Fablj.70004

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