Comparative Law Of Security Interests And Title Finance

W Green has brought together leading figures from both academia and domestic and international practice to write this book, which features a comprehensive commentary on the Arbitration (Scotland) Act 2010

Part of the Law and Practice of International Finance series, this guide provides practical guidance on security interests and title finance in the context of international finance law.This book: - Contains an examination of security interests in nearly all the jurisdictions of the world - Includes summaries, commentaries on security agreements, deal implementation and security packages and analyses the law and practice of security interests worldwide - Gives practical guidance on security interests and title finance in the context of international financial transactions so you can quickly find the best way to proceed - Provides you with a comparative overview of the area in the key jurisdictions of the world so you can apply the law correctly, no matter where the parties are based or operating - Covers key areas of the law and practice of security interests globally including: creation and scope of security interests, including universal charges; publicity, filing and registration; priority of security interests against competing claimants; enforcement of security interests and the impact of insolvency; real property finance, ship and aircraft finance; security over investments, contracts, cash (charge-backs) and intellectual property - Explains the principles of title finance, including financial leasing and repos - Delivers practical commentary on covering security agreements, deal implementation and security packages to assist fast and accurate drafting of agreements

The law of secured transactions has seen dramatic changes in the last decade. International organisations, particularly the United Nations Commission on International Trade Law (UNCITRAL), have been working towards the creation of international legal standards aimed at the modernisation and harmonisation of secured financing laws (eg, the United Nations Convention on the Assignment of Receivables in International Trade, the UNCITRAL Legislative Guide on Secured Transactions and its Intellectual Property Supplement, the UNCITRAL Guide on the Implementation of a Security Rights Registry and the UNCITRAL Model Law on Secured Transactions). The overall theme of this book is international (or cross-border) secured transactions law. It assembles contributions from some of the most authoritative academic voices on secured financing law. This publication will be of interest to those involved in secured transactions around the world, including policy-makers, practitioners, judges, arbitrators and academics.

This book provides a comprehensive survey of the legislative regimes regulating security interests over personal property in the United Kingdom and the major common law jurisdictions of Australia, Canada and New Zealand. The economically important common law jurisdictions of Hong Kong, Malaysia, and Singapore will also be considered.

Comparative Law of Security and Guarantees contains an international and comparative study of the law of security. Coverage includes floating and universal business charges, security over contracts and receivables, charge-backs, security over investment securities including those held by custodians such as Euroclear, a comparative study of ship and aircraft finance, and a review of guarantees, standby letters of credit, comfort letters and so on. The book also contains check-lists, summaries and precedents.

This volume provides coverage of syndicated bank credit agreements and loan transfers, international bond issues including equity-linked bonds, note programs and high yield notes, bondholder trustees and collective action clauses and more.