03444nam 22006371 450 991082156070332120200514202323.01-5099-1437-41-5099-1435-810.5040/9781509914371(CKB)3840000000337079(MiAaPQ)EBC5185042(OCoLC)1004576228(UtOrBLW)bpp09261605(Au-PeEL)EBL5185042(CaPaEBR)ebr11481369(OCoLC)1015873089(EXLCZ)99384000000033707920180302d2018 uy 0engurun#---uuuuatxtrdacontentcrdamediacrrdacarrierCross-border transfer and collateralisation of receivables a comparative analysis of multiple legal systems /Woo-jung JonPortland, Oregon :Hart Publishing,2018.1 online resourceStudies in private international law1-5099-3826-5 1-5099-1434-X Includes bibliographical references and index.1. Introduction -- 2. Security Rights Registries -- 3. Transfers of and Security Rights in Receivables -- 4. Conflicts of Laws and Technical Issues of the Debtor-Indexed Registration System -- 5. The International Receivables Registry -- 6. Priority in the International Receivables Registry -- 7. ConclusionLegal systems around the world vary widely in terms of how they deal with the transfer of and security interests in receivables. The aim of this book is to help international financiers and lawyers in relevant markets in their practice of international receivables financing. Substantively, this book analyses three types of receivables financing transactions, ie outright transfer, security transfer and security interests. This book covers comprehensive comparison and analysis of the laws on the transfer of and security interests in receivables of fifteen major jurisdictions, encompassing common law jurisdictions, Roman-Germanic jurisdictions and French-Napoleonic jurisdictions, as well as relevant EU Directives. To be more specific, this book compares and analyses the relevant legal systems of the US, Canada, New Zealand, Australia, Korea, Japan, France, Belgium, England, Hong Kong, Singapore, China, Germany, Austria and the Netherlands. Furthermore, in order to analyse those legal systems from the international perspective, this book compares relevant international conventions; it also proposes to establish an international registration system for the transfer of and security interests in receivablesStudies in private international law.Accounts receivableConflict of lawsSecurityNegotiable instrumentsPaymentsSecurity (Law)Transfer (Law)Financial lawAccounts receivable.Conflict of lawsSecurity.Negotiable instruments.Payments.Security (Law)Transfer (Law)343.08/7Jon Woo-Jung1976-1700073UtOrBLWUtOrBLWUkLoBPBOOK9910821560703321Cross-border transfer and collateralisation of receivables4082781UNINA