Cross-border Security & Insolvency

This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. It includes private international law and insolvency law issues. Contributions come from leading legal, insolvency and banking specialists drawn from the UK, France, Germany and the US, providing a comparative perspective on each topic discussed.

List of Contributors

xiv

Table of Cases

xv

Tables of Legislation

xxiii

List of Abbreviations

xxxix

Introduction

1

(10)

Robert Stevens

A Banker's Perspective

11

(6)

Lindsay J Town

Taking Security in England

17

(28)

Richard Calnan

Secured Transactions in Personal Property in the United States

45

(14)

Richard F Broude

Taking Security in France

59

(32)

Martin Gdanski

Outline of Security Interests under German Law

91

(32)

Dr Burkhard Jakel

English Conflicts Rules for Transfer of Movables: A Contract-based Approach?

123

(22)

Professor Michael Bridge

German Conflicts Rules on Security Interests in Movable Assets

145

(14)

Professor Ulrich Drobnig

The Conflict of Laws Principles in French Law with Respect to Security Interests in Movable Assets

159

(28)

Professor Catherine Kessedjian

Extraterritorial Impact of Choice of Law Rules for Non-United States Debtors under Revised Uniform Commercial Code Article 9 and a New Proposal for International Harmonization

187

(18)

Professor Charles W Mooney Jun

The English Conflict of Laws Rules

205

(20)

Robert Stevens

The UNIDROIT Mobile Equipment Convention

225

(18)

Professor Sir Roy Goode

An Insolvency Practitioner's Perspective

243

(14)

Mark Homan

The Insolvency Issues

257

Professor Ian F Fletcher

Hamish Anderson

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Cross-border Security & Insolvency

Summary

Table of Contents

Supplemental Materials