Table of Contents
Based on a questionnaire that provided a common framework, this survey focuses on the choice-of-law complexities and substantive similarities and differences involved in international secured transactions. Covering more than 40 jurisdictions, this resource reveals the richness and complexity of commercial law in respect of security interests in financial collateral for international transactions.
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Recognizing a need for a legal guide on the choice-of-law complexities and substantive similarities and differences involved in international secured transactions in financial collateral, members of the UCC Committee's International Law Subcommittee developed a fact pattern and questionnaire that lawyers from G-20 countries, offshore jurisdictions and other countries in Latin America, Europe and Asia completed. This questionnaire provided a common framework through which variations among jurisdictions could be readily identified, thus facilitating cross-border analysis. In one single volume, the scope of the project includes more than 40 jurisdictions worldwide.
Peer reviewed by leading experts, this guidebook is a valuable resource for lawyers working on cross-border secured transactions involving common types of financial collateral: directly held certificated securities; directly held uncertificated securities; securities accounts (and securities credited to them); and deposit accounts. The book dedicates a chapter to each jurisdiction that is surveyed to provide general guidance when negotiating such a secured transaction in that jurisdiction. Carefully edited to enhance comparison, the guide aims to assist lawyers in framing their choice-of-law analysis and helping them to gain insight into the substantive law complexities that can arise in transactions with this type of collateral.
Richard G Paszkiet
ABA Publishing
9781641059930
1028
5070796
7x10 Paperback
8/26/2021 12:00:00 AM
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