Read more
Informationen zum Autor Professor of German and European Private Law and Private International Law at Universität Würzburg, Germany. Klappentext For every transnational lawyer! it is vital to know the differences among national secured transactions law. Since the applicable law is determined by the place where the collateral is situated! it may change when movables are brought from one state to another. Introductory chapters from comparative lawyers set the scene for this topic. The book presents a survey of the law relating to secured transactions in all member states of the European Union. Following the Common Core Approach the national reports are centred around 15 hypotheticals dealing with the most important issues of secured transactions law such as the creation of security rights in different business situations! the relationship between debtor and secured creditor! the nature of the creditor's rights and their enforcement as against third parties. Each case is followed by a comparative summary. A general report evaluates the possibilities of European harmonisation in the field of secured transactions. Zusammenfassung For every transnational lawyer! it is vital to know the differences between national secured transactions laws. Introductory essays from comparative lawyers set the scene. The book then presents a survey of the law relating to secured transactions in the member states of the European Union. Inhaltsverzeichnis Part I. Introduction and context: 1. Introduction Eva-maria Kieninger; 2. A labyrinth of creditors Willem J. Zwalve; 3. Security in movables in the United States Harry C. Sigman; 4. The English law of security Michael Bridge; 5. The European Bank for Reconstruction and Development's Secured Transactions project Frederique Dahan and John Simpson; Part II. The Case Studies; Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger; Indexes....
