Bondholder Rights and Representation in Australia, Germany and the United States

This thesis examines the rights and representation of the holders of corporate bonds in Australia, Germany and the United States, with reference to the laws of England. All provide for some degree of collectivisation of bondholder rights and representation. Different issues are present in each of these two mechanisms, and the various solutions observable in these jurisdictions provide a good comparative scope to assess which rules are more effective and efficient and which less.