Comparing Foreclosure Counseling Policies in the US and UK

This article reviews recent developments in the US and UK in response to rising foreclosures, with an emphasis on the provision of advice or counseling to borrowers in mortgage default. Both nations have increased support for counseling programs despite the lack of evidence that counseling is effective. Based on a quantitative study in the US and a qualitative study in the UK, this article provides preliminary evidence that counseling strategies may be justified. However, the findings from both studies should be approached conservatively. This article also highlights the need for a range of outcome measures for assessing the impact of debt counseling. These studies shed greater light on the ways in which counseling might be beneficial beyond loan cures. Contextual differences between the two countries are identified, and common themes in their policy responses are noted. This article suggests that further insights may be developed through stronger comparative approaches in the analysis of foreclosure prevention policies.