(1) the country imposes restrictions, such as creditors' consent or
minimum dividends to "le for reorganization; (2) secured creditors are able to gain possession of their security once the reorganization petition has been
approved (no automatic stay); (3) secured creditors are ranked first in the distribution of the proceeds that result from the disposition of the assets of
a bankrupt firm; and (4) the debtor does not retain the administration of its property pending the resolution of the reorganization. The index ranges from
zero to four.