This is a discerning analysis of international harmonisation efforts for secured credit law and examines the role of globalisation and finance capital in shaping such efforts.
Gerard McCormack reveals how an ‘efficient’ law is often seen to increase the availability, and lower the cost, of credit, thereby contributing to international development. He considers whether the most comprehensive international standard – the United Nations Commission on International Trade Law (UNCITRAL) Legislative Guide (2008) – is actually suitable for adoption at the national level. In particular, he examines the hypothesis that American law and lawyers have shaped the content of the Guide to the extent that it is not suitable for translation into other laws.
The UNCITRAL Experience
Corporations, Globalisation and the Law series
Chapter 4: National Models and Replication Across International Frontiers – Article 9 of the American Uniform Commercial Law and the English Common Law
Subjects: law - academic, commercial law, company and insolvency law, corporate law and governance, finance and banking law, international commercial law
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