Orlando

Description

As cross-border trade and cross-border financing continue to increase, and

while security rights over tangible property are governed by the law of the

place where the moveable is situated, comparative knowledge of national

secured transactions law is crucial for everyone using security rights over

tangibles in a cross-border context. This book provides an in-depth

examination of the key issues that arise when security rights are created,

perfected, and enforced in different European countries. Authored by

experts on German, English, Dutch, French, Belgian, Italian, and Spanish

law, the national reports use practical cases and highlight differences and

similarities. A special focus is placed on the way in which national courts

deal with security interests created elsewhere. A comprehensive

introductory chapter analyzes significant secured transactions issues,

summarizes the comparative data and compares them with Article 9 of the

Uniform Commercial Code (U.S.) and suggests guiding principles for a

European harmonization measure or national reform efforts. The book will

assist market participants and their counsel to better understand secured

transactions law and relevant private international law rules of their own

and other countries, and will assist those involved in national, EU, and

global law reform efforts.ò