Security Rights in Movable Property in European Private Law by Eva-Maria Kieninger, Michele Graziadei, George L. Gretton,

By Eva-Maria Kieninger, Michele Graziadei, George L. Gretton, Cornelius G. van der Merwe, Matthias E. Storme

The publication offers a survey of the legislation with regards to secured transactions in all member states of the ecu Union. Following the typical center procedure, the nationwide experiences are based round 15 hypothetical situations facing crucial problems with secured transactions legislation akin to the construction of safety rights in numerous company events, the connection among debtor and secured creditor, the character of the creditor's rights and their enforcement as opposed to 3rd events. each one case is by way of a comparative precis. A basic document evaluates the probabilities of eu harmonization.

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It is likely that a higher interest rate drives the more trustworthy debtors out of the market, a fact that will be anticipated by creditors. Thus, the amount of available credit may decrease as a consequence of a higher interest rate, although usually the amount of goods offered increases with the price. Security rights may overcome this problem by enabling the creditor to inform himself better about the debtor’s creditworthiness. 8 While it can safely be said that a secured transaction either benefits the two contracting parties or at least does not harm their interests, the picture changes once the interests of other, unsecured creditors are taken into consideration.

A. Cf. ); Ulrich Drobnig, ‘Security Rights in Movables’, in: Arthur Hartkamp et al. ), Mobiliarsicherheiten -- Vielfalt oder Einheit? (1999); Sixto Sánchez Lorenzo, Garantías reales en el comercio internacional (1993); Herbert Stumpf, Eigentumsvorbehalt und Sicherungsübertragung im Ausland (4th edn, 1980); Anna Veneziano, Le garanzie mobiliari non possessorie (2000); and the series Recht der Kreditsicherheiten in den europäischen Ländern edited by Walther Hadding and Uwe Schneider (from 1978). ; Theophile Margellos, La protection du vendeur à crédit d’objets mobiliers corporels à travers la clause de réserve de propriété, Étude de droit comparé (1989); P.

See Hellmich, Kreditsicherungsrechte in der spanischen Mehrrechtsordnung 85 ff. For details see Drobnig, ‘Security over Corporeal Movables in Germany’, in: J. G. ), Security over Corporeal Movables (1974) 181 at 187 ff. Cf. RG 9 Oct. 1880, RGZ 2, 168; RG 17 Mar. 1885, RGZ 13, 298 (on the basis of the French Code civil); RG 10 Jan. 1885, RGZ 13, 200; RG 2 June 1890, RGZ 26, 180. See also infra, chapter 2, Zwalve, ‘A labyrinth of creditors’, pp. 50 f. Cf. RG 8 Nov. 1904, RGZ 59, 146. See also infra, German report, case 10(a).

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