Yet the more proscriptive European vision may better suit consumer and industry demands for certainty.

ECONOMIST: Charlemagne

While this focus may be justified, it is fundamentally more reactive than proscriptive.

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Under Engish insolvency law, which is less proscriptive than Ireland's new guidelines, "reasonable" day-to-day expenses for bankrupts include holidays, mobile phones and video rentals.

CNN: Ireland picks through debtors' lifestyles