Teemu Juutilainen, Secured Credit in Europe: From Conflicts to Compatibility
| DOI | 10.3366/elr.2020.0663 |
| Published date | 01 September 2020 |
| Date | 01 September 2020 |
| Pages | 447-448 |
| Author |
Reform of security over moveable property has become a subject of increasing interest internationally in recent times. It is now generally accepted that a modern secured transactions law brings economic benefit. Lenders typically will offer loans at lower interest rates where assets are available over which security can be taken. But for moveable property there is a particular challenge. The clue is in the name. Moveable assets move. This raises important questions. Will a security right created over vehicles in Germany subsist if these are driven to Scotland? And how best could security be taken over assets owned by a multi-national company in multiple jurisdictions? These are the issues which provide the background to Teemu Juutilainen's impressive book, which is based on his doctoral thesis completed in 2015 at the University of Helsinki. Its aim is to find the optimal path to compatibility between the laws of European countries in relation to (a) security over corporeal moveables (as we would call these in Scotland) and (b) receivables.
The book provides a detailed analysis of the existing literature in the area which has been written in recent years in English, German, the Scandinavian languages and Finnish. By doing this the author already provides a service to those such as this reviewer whose foreign language skills are considerably more...
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