By Eva-Maria Kieninger, Michele Graziadei, George L. Gretton, Cornelius G. van der Merwe, Matthias E. Storme
The ebook offers a survey of the legislations with regards to secured transactions in all member states of the ecu Union. Following the typical middle strategy, the nationwide stories are founded round 15 hypothetical instances facing an important problems with secured transactions legislation reminiscent of the production of defense rights in numerous company occasions, the connection among debtor and secured creditor, the character of the creditor's rights and their enforcement as opposed to 3rd events. every one case is by way of a comparative precis. A basic document evaluates the probabilities of ecu harmonization.
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Additional info for Security Rights in Movable Property in European Private Law (The Common Core of European Private Law)
Sample text
Some, however, are content with mere formal requirements. 46 The other basic model is the use of ownership for security purposes, be it in the form of a security transfer of ownership, security assignment, retention of title, hire purchase or a leasing contract. With these types of security interest, the parties are frequently given greater autonomy to shape their legal relationship according to their particular needs. 47 Overall, there is a tendency to accept hire-purchase and leasing agreements and even (simple) retention of title without placing these arrangements under the same restrictive conditions applicable to the possessory, or indeed non-possessory, pledge.
Mayer, JCP 1981 I 3019 (para. ); Ritterhoff, Parteiautonomie im internationalen Sachenrecht; Staudinger/Stoll, Internationales Sachenrecht nos 282 ff. ; Stoll, IPRax 2000, 259 (264); Weber, RabelsZ 44 (1980) 510 (524). Cf. further the summaries in Kaufhold, Internationales und europäisches Mobiliarsicherungsrecht 159 ff. and Rott, Vereinheitlichung des Rechts der Mobiliarsicherheiten 25 ff.
See Hellmich, Kreditsicherungsrechte in der spanischen Mehrrechtsordnung 85 ff. For details see Drobnig, ‘Security over Corporeal Movables in Germany’, in: J. G. ), Security over Corporeal Movables (1974) 181 at 187 ff. Cf. RG 9 Oct. 1880, RGZ 2, 168; RG 17 Mar. 1885, RGZ 13, 298 (on the basis of the French Code civil); RG 10 Jan. 1885, RGZ 13, 200; RG 2 June 1890, RGZ 26, 180. See also infra, chapter 2, Zwalve, ‘A labyrinth of creditors’, pp. 50 f. Cf. RG 8 Nov. 1904, RGZ 59, 146. See also infra, German report, case 10(a).