Statutory solutions have been adopted or proposed in a few countries

• Process based solutions – mimic national corporate debt restructuring frameworks

➢ xamples: IMF staff’s SDRM proposal in 20-3 and NY draft bill 2021

• Recovery based solutions – limit recovery to specified amount

➢ Examples: UK Debt Relief Act 2010, Belgium Anti-Vulture Law, NY draft bill 2022

• Asset based solutions – limit to seizing certain sovereign assets

➢ Examples: FrenchAnti-Vulture Law 2016, Iraq (UN Security Council Resolution)

• Several bills have been proposed in New York State to regulate the process and/or enforcement of sovereign debt

➢ 2021 Bill: Proposes a statutory process governed by NY state law to restructure all NY-law governed sovereign claims (like a bankruptcy law for sovereigns)

➢ 2022 Bill: Building on the model of the UK’s Debt Relief ct (2010), bill proposes limiting the recoverability of NY lawgoverned claims to debt relief provided by the official sector (e.g., through Common Framework).

➢ CSOs have also been garnering legislative support to revive the “Champerty” Doctrine (which prohibits the purchase of debt for purposes of bringing a lawsuit)

• Support outside of the CSO community appears limited and no current indication they will be considered in the near term by the New York legislature

• Issues include interaction with current international sovereign debt architecture, market implications and legal certainty