Floating Charges in Comparative Perspective

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

Edited by Alisdair MacPherson, Senior Lecturer in Commercial Law, University of Aberdeen, UK and Caroline Sophie Rapatz, Professor of Civil Law, European and International Private and Procedural Law and Comparative Law, Christian Albrechts University of Kiel, Germany