Floating Charges in Comparative Perspective / Alisdair MacPherson and Caroline Sophie Rapatz, editors.

Format:

Book

Contributor:

MacPherson, Alisdair, editor.

Rapatz, Caroline Sophie, editor.

Edward Elgar Publishing, publisher.

Language:

English

Subjects (All):

Commercial law.

Corporations--Finance--Law and legislation.

Corporations.

Physical Description:

1 online resource (0 pages)

Edition:

First edition.

Place of Publication:

Northampton : Edward Elgar, 2025.

Summary:

"This edited collection examines floating charges, a special type of security that covers a class of revolving assets, and functional equivalents across the world. The book explores common threads and points of disparity in how floating charges are used and regulated across different jurisdictions, drawing on expert insights in the field of security rights. It includes a wide-ranging comparative overview of floating charges in 40 jurisdictions, as well as chapters which discuss the historical, doctrinal and practical contexts surrounding floating security within the legal systems of selected jurisdictions in Africa, Asia, Europe and North America. The authors analyse discrete aspects of relevant security rights including creation rules, digital assets, the encumbrance of intermediated securities and wider property law issues. Floating Charges in Comparative Perspective is a valuable resource for academics and students in commercial law, company and insolvency law, comparative law and property law. Additionally, it is beneficial to legislators, policymakers and practitioners, particularly those involved in cross-border secured transactions"-- Provided by publisher.

Contents:

Contents: Introduction to floating charges in comparative perspective / Alisdair MacPherson and Caroline Sophie Rapatz

1. A comparative overview of floating charges and functional equivalents / Alisdair MacPherson and Caroline Sophie Rapatz

2. Floating charges in England / Andreas Televantos

3. The evolution of floating charges in Ghana, Kenya and nigeria / Chike Emedosi

4. The decisive influence of publicity on the historical development of continental European floating security rights / Vincent van Hoof

5. The general hypothecation of movable property in South African law / Reghard Brits

6. The floating lien in American law: From historical accounts to digital assets / Christopher K. Odinet

7. The floating charge in Chinese law: Following the english model? / Zhicheng Wu and Hao Zhang

8. The english floating charge and the conceptualisation of a French global security / Muriel Renaudin

9. Floating security in québec? Hypothecs on a universality of movable property / Catherine Walsh

10. Drifting in the currents: Floating charges under Romanian law / Radu Rizoiu

11. The short history of the Hungarian floating security / Tibor Tajti

12. Floating charges in the nordic countries / Bjørn Løtveit, Astrid Millung-Christoffersen, Patrik Lindskoug and Teemu Juutilainen

13. The encumbrance of intermediated securities in Switzerland / Alexandra Dal Molin-Kränzli.

Notes:

Includes bibliographical references and index.

Description based on publisher supplied metadata and other sources.

Description based on print version record.

ISBN:

1-03-531714-1

OCLC:

1519124063