基本説明
The book makes comparisons of international instruments by using the English and US laws.
Full Description
This book focuses on international harmonisation and the law of secured transactions by distilling and analysing the unifying principles of various significant international conventions and instruments such as the UN Convention on the Assignment of Receivables, the Unidroit Convention on International Factoring, the EBRD Model Law on Secured Transactions, the Unidroit Convention on the International Interests in Mobile Equipment and the UNCITRAL Legislative Guide on Secured Transactions.
International secured transactions conventions and instruments facilitate credit and promote economic activity through the creation of harmonised rules. Therefore, given the increasing globalisation of markets, international reform efforts for the harmonised modernisation of secured transactions law have gained pace over recent years. International Secured Transactions Law draws on experiences in both English and US laws in order to identify and illustrate the existing problems that need to be addressed, as well as identify potential solutions.
International Secured Transactions Law will be of interest to scholars, students interested in international commercial law, corporate law or comparative secured transactions, and practitioners involved in international commercial transactions.
Contents
Introduction 1. Secured Credit and Fundamental Principles of International Instruments 2. Harmonisation of Secured Transactions Law in Context 3. Scope of Applicability and Party Autonomy 4. Creation of Security Rights 5. Effectiveness of Security Interests against Third Parties 6. Priority of Security Interests 7. Acquisition Financing Devices 8. Choice of Law Issues. Conclusion
