• 1 Introduction
  • 2 The narrative: what happened differently in the United States
  • 2.1 The construction boom created excess supply
  • 2.2 Lending standards seem to have eased more in the United States
  • 2.3 Arrears rates deteriorated before the economy did
  • 3 Understanding the institutional drivers of the differences
  • 3.1 Supply of new housing is relatively exible
  • 3.2 Tax system encourages higher leverage and ipping
  • 3.3 Legal system is swift but generous to defaulters
  • 3.4 Lenders could rely on external credit scores
  • 3.5 Financial regulation did not prevent riskier lending
  • 3.6 Cash-out renancing is inexpensive in the United States
  • 3.7 Structured nance enabled subprime and other non-conforming lending
  • 4 Concluding remarks and some policy lessons