Cross-border Security and Insolvency

This volume analyzes the legal and practical issues that arise in cross-border transactions involving the taking and enforcement of security over movable and intangible property. Having analyzed the domestic law of security in the UK, US, France and Germany, it then focuses upon the private international law and insolvency law issues. Contributions come from leading legal, insolvency and banking specialists drawn from the relevant jurisdictions, providing a comparative perspective on each topic discussed. Coverage includes a focused, practical, case-study plus input from banking and insolvency professionals.

2. A BANKER'S PERSPECTIVE ; 3. TAKING SECURITY IN ENGLAND ; 7. ENGLISH CONFLICT RULES FOR TRANSFERS OF MOVABLES: A CONTRACT-BASED APPROACH ; 12. THE UNIDROIT MOBILE EQUIPMENT CONVENTION ; 13. AN INSOLVENCY PRACTITIONER'S PERSPECTIVE ; APPENDICES ; THE COLLOQUIUM CASE STUDY ; ARTICLE 9 OF THE UNIFORM COMMERCIAL CODE (SELECTED PROVISIONS) ; COUNCIL REGULATION (EC) NO 1346/2000 OF 29 MAY 2000 ON INSOLVENCY PROCEEDINGS ; UNIDROIT CONVENTION ON INTERNATIONAL INTERESTS IN MOBILE EQUIPMENT ; PROTOCOL TO THE UNIDROIT CONVENTION ON INTERNATIONAL INTERESTS IN MOBILE EQUIPMENT ON MATTERS SPECIFIC TO AIRCRAFT EQUIPMENT