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Why aren't there more foreclosures in Europe?

Dwight Jaffee shows that mortgage foreclosures in Europe are still rare, even in distress countries such as Spain and the United Kingdom.  The question is why.  I have heard people in seminars suggest that it is because of recourse--it is ubiquitous in Europe.  But perhaps it is because the social safety net in Europe is stronger.   When Americans lose their jobs, it is hard for them to make mortgage payments.  When Europeans lose their jobs, it is still hard, but perhaps less so than in the US.  Just a thought....
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