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This text is comprised of a collection of papers dealing with various aspects of cross-border secured transactions, an important issue in the development of emerging financial markets and transitional market economies. The papers stress the importance of the development of a sound legal framework.
Sommario
Part 1 General issues in the law of secured transactions: the changing nature of security rights, R.M. Goode; a compartive introduction to security over movables and intangibles, U. Drobnig; economic functionsof security in a market economy, H.W. Fleisig; world-wide security - classification of jurisdictions, P.R.Wood; classification of security interests on the highways of international commerce, O. Hartwieg; the conditional sale is alive and well, J.H. Dalhuisen. Part 2 Law reform in the filed of secured transactions: general principles of a modern secured transactions law, J.L.Simpson, J.-H.M. Rover; a functional analysis of the EBRD model law on secured transactions, J.A. Spanogle; the model law on secured transactions of the EBRD form a German point of view, K. Kreuzer; the EBRD model law and the Hungarian law, A. Harmathy; UNCITRAL's work in the field of secured transactions, S.V. Bazinas; credit security and debt recovery - law's role in reform in Asia and the Pacific, R. Cranston; difficulties for obtaining secured lending in Latin America - why law reform really matter, A.M. Garro. Part 3 Security interests and issues - examples from selected jurisdictions: selected security interests in the United States, P. Winship; mixed systems- Scotland, G.L. Gretton; security issues under Russian law, A.Zverev; secured financing issues for international lenders - bridging the gap between the civil and common law through asset-backed securitisation - lessons from and respecting Argentina and Mexico, D.W. Banowsky, J.J. Norton; the Japanese approach, M. Yanaga; enforcing security in India, Sri Lanka and Malaysia, S.Abeyratne; overviews of laws relating to security interests in Vietnam, T. Whitehead and Le Thu Hang; China's new security law - a close look, L. Barale. Appendices: EBRD model law on secured transactions; UNCITRAL draft convention on assignment in receivables financing; revised draft of articles of a future UNIDROIT convention on international interests in mobile equipment.
