Publisher's Synopsis
Security Interests in Mobile Equipment consists of a series of essays examining the legal security aspects in asset finance, consumer credit and personal property law. It is divided into three parts. The first examines the concept of security within domestic law. The second considers the choice of law rule in respect of mobile assets subject to security interests which move between frontiers. The final part reviews the development of uniform law, particularly a body of international substantive law that addresses the central legal elements of cross-border security financing and leasing of high-value mobile equipment. In international transactions insolvency involving assets subject to security interests moving between national frontiers, the differences in principles which apply to secured credit in various jurisdictions is staggering. However, the draft Convention prepared by UNIDROIT/ICAO dealing with security interests in mobile equipment suggests that an international legal framework presenting a system for securing loans is now emerging.
