Subjects:

Insolvency Law

Contents:

Foreword by the Rt. Hon. the Lord Millett

1. Introduction

2. A BANKER'S PERSPECTIVE

3. TAKING SECURITY IN ENGLAND

4. Secured Transactions in Personal Property in the United States

5. Taking Security in France

6. Outlines of Security Interests under German Law

7. ENGLISH CONFLICT RULES FOR TRANSFERS OF MOVABLES: A CONTRACT-BASED APPROACH

8. German Conflicts Rules on Security Interests in Movable Assets

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

10. 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

11. The English Conflict of Laws Rules

12. THE UNIDROIT MOBILE EQUIPMENT CONVENTION

13. AN INSOLVENCY PRACTITIONER'S PERSPECTIVE

14. The Insolvency Issues

APPENDICES

THE COLLOQUIUM CASE STUDY

ARTICLE 9 OF THE UNIFORM COMMERCIAL CODE (SELECTED PROVISIONS)

COUNCIL REGULATION (EC) NO 1346/2000 OF 29 MAY 2000 ON INSOLVENCY PROCEEDINGS

UNIDROIT CONVENTION ON INTERNATIONAL INTERESTS IN MOBILE EQUIPMENT

PROTOCOL TO THE UNIDROIT CONVENTION ON INTERNATIONAL INTERESTS IN MOBILE EQUIPMENT ON MATTERS SPECIFIC TO AIRCRAFT EQUIPMENT

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. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the private international law and insolvency law issues.

Contributions come from leading legal, insolvency and banking specialists drawn from the relevant jurisdictions, providing a comparative perspective on each topic discussed. Coverage includes a focused, practical, case-study plus input from banking and insolvency professionals.