Publisher's Synopsis
Recognizing a need for a legal guide on the choice-of-law complexities and substantive similarities and differences involved in international secured transactions in financial collateral, members of the UCC Committee's International Law Subcommittee developed a fact pattern and questionnaire that lawyers from G-20 countries, offshore jurisdictions and other countries in Latin America, Europe and Asia completed. This questionnaire provided a common framework through which variations among jurisdictions could be readily identified, thus facilitating cross-border analysis. In one single volume, the scope of the project includes more than 40 jurisdictions worldwide. Peer reviewed by leading experts, this guidebook is a valuable resource for lawyers working on cross-border secured transactions involving common types of financial collateral: directly held certificated securities; directly held uncertificated securities; securities accounts (and securities credited to them); and deposit accounts. The book dedicates a chapter to each jurisdiction that is surveyed to provide general guidance when negotiating such a secured transaction in that jurisdiction. Carefully edited to enhance comparison, the guide aims to assist lawyers in framing their choice-of-law analysis and helping them to gain insight into the substantive law complexities that can arise in transactions with this type of collateral.
