A Review of European Direct Lending (Third of a Series)

“Europe is not a market,” a keen observer of Europe’s debt market informed us. “First of all,” he said, “there’s the difference in legal jurisdictions. These are real hurdles and won’t change anytime soon. If anything, the EU is becoming less unified.”

“Here local teams matter. Even London-based teams have trouble managing deals on the continent. The more complex the structure, the more local the team needs to be.”

Understanding the nuances of local companies is critical, particularly in a default, an attorney specializing in cross-border matters told us. “Your options as a lender are very different in Italy versus Spain or France. There’s no one standard approach.”

He went on. “The Scandinavian countries are somewhat similar to the UK. They are supportive of their borrowers. But southern Europe is very different. Each country has its own dangers and dilemmas. Laws are evolving quite rapidly post-crisis.”