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Floating Charges in Comparative Perspective

Edited by: Alisdair MacPherson, Caroline Sophie Rapatz

ISBN13: 9781035317134
To be Published: April 2025
Publisher: Edward Elgar Publishing Limited
Country of Publication: UK
Format: Hardback
Price: £150.00



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

Subjects:
Banking and Finance
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