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The Common Core of European Private Law : Security Rights in Movable Property in European Private Law - Eva-Maria Kieninger

The Common Core of European Private Law

Security Rights in Movable Property in European Private Law


Published: 27th September 2004
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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 centered 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.

'The volume is a profound comparative study which discusses the main problems of the European law of security rights in movable property in depth. ... The study ... is a valuable contribution to scholarship in the field of security law, but also to comparative property law in general. The neutral and descriptive approach of the study constitutes a good basis for further scholarly and political discussions on the harmonisation of security law. The case-orientated approach makes it also a good device for legal education. The volume thus can serve as a useful basis for a course or seminar on comparative property law. The picture that is drawn shows clearly that there is space and need for activity by the European Union.' Maastricht Journal of European and Comparative Law

Introduction and context
A labyrinth of creditors
Security in movables in the United States
The English law of security
The European Bank for Reconstruction and Development's Secured Transactions project
The Case Studies
Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations
Table of Contents provided by Publisher. All Rights Reserved.

ISBN: 9780521839679
ISBN-10: 052183967X
Series: The Common Core of European Private Law
Audience: Professional
Format: Hardcover
Language: English
Number Of Pages: 828
Published: 27th September 2004
Publisher: Cambridge University Press
Country of Publication: GB
Dimensions (cm): 23.4 x 15.6  x 4.4
Weight (kg): 1.33