CEU eTD Collection (2009); Maresova, Katerina: INVESTMENT PROPERTY AS COLLATERAL: BASIC DIFFERENCES BETWEEN CZECH AND US LAW

CEU Electronic Theses and Dissertations, 2009
Author Maresova, Katerina
Title INVESTMENT PROPERTY AS COLLATERAL: BASIC DIFFERENCES BETWEEN CZECH AND US LAW
Summary This thesis investigates the use of investment property as collateral in the direct and indirect securities holding systems.
This thesis shows shift from direct holding system towards indirect holding system of securities in US and direct holding system in the Czech Republic. The thesis furthermore discusses the creation, perfection and enforcement of the security interest in investment property governed by Article 9 UCC and compares it with the relevant regulations in the Czech Republic. The differences in both legal systems are assessed with regard to what lessons could be learned from Article 9 UCC solution.
Some aspects related to the investment property collateral inherent in US law of secured transactions for example, the priority rules and possible tolerance to the secret lien are also examined. Additionally, special attention is devoted to recent implementation of the financial collateral to the Czech legal system in compliance with the Financial Collateral Directive.
Supervisor Prof. Tibor Tajti, S.J.D.
Department Legal Studies LLM
Full texthttps://www.etd.ceu.edu/2009/maresova_katerina.pdf

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