Counselling the Overindebted: A Comparative Perspective


Saul Schwartz


Office of the Superintendent of Bankruptcy (OSB)




Counselling for overindebted or insolvent individuals can take many forms. In this paper, the structure of debt counselling in several different national systems is reviewed. The goal is to place the Canadian system in an international context so that any reforms that might be considered in Canada can informed by the experience of other countries. After this introduction, Section II presents an overview of the Canadian system and then briefly summarizes the major similarities and differences between North American and European debt counselling. Section III presents a rough typology of debt counselling organizations, dividing them into process-oriented, rights-based and educational groups. Section IV looks in some detail at debt counselling systems in Germany, the United Kingdom and in Ireland. Conclusions appear in the final section.

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Contact information

Office of the Superintendent of Bankruptcy 
Heritage Place
155 Queen Street, 4th Floor
Ottawa, Ontario  K1A 0H5
(613) 941-1000
(613) 941-2862

Source: Consumer Policy Research Database

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