5. Conclusions and policy considerations
This paper explored the phenomenon of higher launch spreads of dollar-denominated sovereign bonds issued under U.K. governing law when compared to those under U.S. governing law. This effect was not evident before the global financial crisis of 2008. Even after controlling for bond characteristics or macroeconomic variables, differences between the United States and U.K.'s legal systems, seem important in explaining bond-pricing differences. The difference in spreads persists in the secondary market even after 180 days. We tested some plausible explanations for the spread difference between bonds governed by these two legal jurisdictions. Collective action clauses contributed to higher spreads, but only before the crisis. In fact, post-crisis, CACs are almost equally prevalent in both jurisdictions. Also, the difference in spreads arose due to a lowering of spreads of U.S. governing law bonds after the crisis. Furthermore, it is SEC registration that drives the spread difference. We argue that in the post-crisis period, higher compliance costs and disclosure requirements associated with SEC registration and U.S. law listing may have encouraged some issuers to opt for the U.K. law. On average, bonds issued under U.K. law had weaker ratings and shorter tenors in the post-crisis period, indicating issuers with weaker creditworthiness.