The recent downturn of the global economy, spurred in large part by an unparalleled housing crisis and credit crunch in the United States and abroad, cannot be practicably understood or explained by an examination of isolated factors. Although the impact of the economic downturn has been felt globally, many blame the meltdown of the U.S. subprime mortgage market for their individual country's woes. Therefore, the mortgage regulatory scheme in the United States, in terms of lending practices and housing policies, is an important place to begin an inquiry into the origins of the global crisis. In order to better understand how the lending practices in the United States may have contributed to the housing crisis, and furthermore, to hypothesize potential solutions to prevent such events from recurring, it is valuable to examine the housing and lending policies of other economies. This paper aims to compare and contrast certain aspects of generally accepted lending practices in the United States and the United Kingdom, including recent changes in regulation that are targeted at making the lending process more transparent. The ultimate conclusion of this inquiry is that the time has arrived for the United States to look across the Atlantic for inspiration in terms of regulating mortgages.
Transparency in Lending in the United States and the United Kingdom: Which Business Model Does It Best,
Nw. J. Int'l L. & Bus.