Suchergebnisse

The two jurisdictions with the greatest volume and complexity of laws dealing with usury are the United States and Israel. England, the wellspring of our common law, and one of present-day Israel's legal fonts, did away with all regulation of interest over a century ago. All of continental Europe contains only two or three jurisdictions which apply legal limits to interest on loans. The communist countries present a special situation since private loans at interest have no official place in the economic system. Islamic countries, like Pakistan, constitutionally frown on interest but it is present in practice, thereby embarrassing the secular authorities. However, the extent of legal experience with loans at interest in all other jurisdictions combined does not rival that wealth of elaborate study which is to be found in judicial decisions and legislative documents in American and Jewish law. It is, therefore, of interest to examine from a comparative standpoint the approach to usury taken by United States' courts and by Jewish legal authorities to see in which respects they differ and are similar.