http://online.wsj.com/article/SB1000...LEFTTopStories

Europe's issues with bankruptcy are highlighted in this article from the Wall Street Journal. In Ireland at present a person can take up to twelve years to come out of bankruptcy and at that they must during that period give all their disposable income to creditors. The new legislation that comes in will bring this down to three years but is it enough? Spain is even worse when it comes to such situations debts never die and must be paid which can make a situation worse when renting an apartment or taking out a mobile contract. The best way of describing it is that a person can be essentially blacklisted. The situation is also fairly dodge in Netherlands and Denmark. All of this is in stark contrast to the US where people can turn the key and give their properties back to their banks. People have a credit rating that may be shot to bits and banks take a hit but people are left realtively unscathed, can we take anything from the American model?