Two continents separated by a common language? Harmonising US and European loans

Loan terms that were once predominantly a feature of US loan agreements have over the last decade been more frequently imported into European loan agreement. It has now become common in the European syndicated term loan B (TLB) marker to include "blended" terms where English law loan agreements incorporate terms and concepts more typical of US loans. Differences do remain across the two markets and  we will conduct a comparison exercise at the end of this article to show how key terms vary.

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