Emerging Financial Markets and Secured Transactions

ISBN: 9789041106759 出版年：1998 页码：592 Kluwer Law International

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.