Buy Floating Charges in Comparative Perspective by Alisdair MacPherson
close menu
Bookswagon
search
My Account
Home > Laws of specific jurisdictions > Financial law: general > Capital markets and securities law and regulation > Floating Charges in Comparative Perspective
Floating Charges in Comparative Perspective

Floating Charges in Comparative Perspective


     0     
5
4
3
2
1



Available


X
About the Book

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 security in 40 jurisdictions, as well as chapters which discuss the historical, doctrinal and practical contexts surrounding such 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.



Table of Contents:
Contents Introduction to Floating Charges in Comparative Perspective 1 Alisdair MacPherson and Caroline Sophie Rapatz 1 A comparative overview of floating charges and functional equivalents 12 Alisdair MacPherson and Caroline Sophie Rapatz 2 Floating charges in England 86 Andreas Televantos 3 The evolution of floating charges in Ghana, Kenya and Nigeria 109 Chike Emedosi 4 The decisive influence of publicity on the historical development of continental European floating security rights 151 Vincent van Hoof 5 The general hypothecation of movable property in South African law 180 Reghard Brits 6 The floating lien in American law: from historical accounts to digital assets 200 Christopher K. Odinet 7 The floating charge in Chinese law: following the English model? 233 Zhicheng Wu and Hao Zhang 8 The English floating charge and the conceptualisation of a French global security 253 Muriel Renaudin 9 Floating security in Québec? Hypothecs on a universality of movable property 284 Catherine Walsh 10 Drifting in the currents: floating charges under Romanian law 316 Radu Rizoiu 11 The short history of the Hungarian floating security 340 Tibor Tajti 12 Floating charges in the Nordic countries 371 Bjørn Løtveit, Astrid Millung-Christoffersen, Patrik Lindskoug and Teemu Juutilainen 13 The encumbrance of intermediated securities in Switzerland 403 Alexandra Dal Molin-Kränzli

About the Author :
Edited by Alisdair MacPherson, Senior Lecturer in Commercial Law, University of Aberdeen, UK and Caroline Sophie Rapatz, Professor of Civil Law, European and International Private and Procedural Law and Comparative Law, Christian Albrechts University of Kiel, Germany

Review :
‘An important text that will be valuable to policy makers, legislators, academics, and practitioners and will be particularly useful to those individuals and institutions that engage in cross-border secured transactions, whether from a regulatory, practical, or educational perspective.’ ‘A comprehensive and timely examination of floating charges and their functional equivalents across more than 40 jurisdictions. Combining empirical comparative research with detailed national studies, the volume illuminates how different legal systems conceptualise, implement, and regulate non‑possessory security interests that enable businesses to use and dispose of assets in the ordinary course of trade until crystallisation.’ ‘This book offers an excellent overview of how a security right can be established on continuously changing assets. It provides insights into the problems this presents from a more restricted approach to property rights. The topic is analysed across legal traditions, and the history of floating security rights is examined, with a broad global overview that includes Africa, China, Europe and North America – an impressive work of global comparative property law analysis.’


Best Sellers


Product Details
  • ISBN-13: 9781035317134
  • Publisher: Edward Elgar Publishing Ltd
  • Publisher Imprint: Edward Elgar Publishing Ltd
  • Height: 234 mm
  • No of Pages: 444
  • ISBN-10: 1035317133
  • Publisher Date: 29 Apr 2025
  • Binding: Hardback
  • Language: English
  • Width: 156 mm


Similar Products

Add Photo
Add Photo

Customer Reviews

REVIEWS      0     
Click Here To Be The First to Review this Product
Floating Charges in Comparative Perspective
Edward Elgar Publishing Ltd -
Floating Charges in Comparative Perspective
Writing guidlines
We want to publish your review, so please:
  • keep your review on the product. Review's that defame author's character will be rejected.
  • Keep your review focused on the product.
  • Avoid writing about customer service. contact us instead if you have issue requiring immediate attention.
  • Refrain from mentioning competitors or the specific price you paid for the product.
  • Do not include any personally identifiable information, such as full names.

Floating Charges in Comparative Perspective

Required fields are marked with *

Review Title*
Review
    Add Photo Add up to 6 photos
    Would you recommend this product to a friend?
    Tag this Book Read more
    Does your review contain spoilers?
    What type of reader best describes you?
    I agree to the terms & conditions
    You may receive emails regarding this submission. Any emails will include the ability to opt-out of future communications.

    CUSTOMER RATINGS AND REVIEWS AND QUESTIONS AND ANSWERS TERMS OF USE

    These Terms of Use govern your conduct associated with the Customer Ratings and Reviews and/or Questions and Answers service offered by Bookswagon (the "CRR Service").


    By submitting any content to Bookswagon, you guarantee that:
    • You are the sole author and owner of the intellectual property rights in the content;
    • All "moral rights" that you may have in such content have been voluntarily waived by you;
    • All content that you post is accurate;
    • You are at least 13 years old;
    • Use of the content you supply does not violate these Terms of Use and will not cause injury to any person or entity.
    You further agree that you may not submit any content:
    • That is known by you to be false, inaccurate or misleading;
    • That infringes any third party's copyright, patent, trademark, trade secret or other proprietary rights or rights of publicity or privacy;
    • That violates any law, statute, ordinance or regulation (including, but not limited to, those governing, consumer protection, unfair competition, anti-discrimination or false advertising);
    • That is, or may reasonably be considered to be, defamatory, libelous, hateful, racially or religiously biased or offensive, unlawfully threatening or unlawfully harassing to any individual, partnership or corporation;
    • For which you were compensated or granted any consideration by any unapproved third party;
    • That includes any information that references other websites, addresses, email addresses, contact information or phone numbers;
    • That contains any computer viruses, worms or other potentially damaging computer programs or files.
    You agree to indemnify and hold Bookswagon (and its officers, directors, agents, subsidiaries, joint ventures, employees and third-party service providers, including but not limited to Bazaarvoice, Inc.), harmless from all claims, demands, and damages (actual and consequential) of every kind and nature, known and unknown including reasonable attorneys' fees, arising out of a breach of your representations and warranties set forth above, or your violation of any law or the rights of a third party.


    For any content that you submit, you grant Bookswagon a perpetual, irrevocable, royalty-free, transferable right and license to use, copy, modify, delete in its entirety, adapt, publish, translate, create derivative works from and/or sell, transfer, and/or distribute such content and/or incorporate such content into any form, medium or technology throughout the world without compensation to you. Additionally,  Bookswagon may transfer or share any personal information that you submit with its third-party service providers, including but not limited to Bazaarvoice, Inc. in accordance with  Privacy Policy


    All content that you submit may be used at Bookswagon's sole discretion. Bookswagon reserves the right to change, condense, withhold publication, remove or delete any content on Bookswagon's website that Bookswagon deems, in its sole discretion, to violate the content guidelines or any other provision of these Terms of Use.  Bookswagon does not guarantee that you will have any recourse through Bookswagon to edit or delete any content you have submitted. Ratings and written comments are generally posted within two to four business days. However, Bookswagon reserves the right to remove or to refuse to post any submission to the extent authorized by law. You acknowledge that you, not Bookswagon, are responsible for the contents of your submission. None of the content that you submit shall be subject to any obligation of confidence on the part of Bookswagon, its agents, subsidiaries, affiliates, partners or third party service providers (including but not limited to Bazaarvoice, Inc.)and their respective directors, officers and employees.

    Accept

    Fresh on the Shelf


    Inspired by your browsing history


    Your review has been submitted!

    You've already reviewed this product!
    Your IP: 216.73.216.196 IN