Prerequisite: None

Exam Type: In Class

Secured transactions are a fundamental part of international finance. And yet, two of the leading international finance centres, the US and the UK, have radically different systems. In this seminar we will explore the US asset-based secured transactions law regime in a comparative frame with the UK’s enterprise regime. We will focus on some of the challenges that arise with an asset-based regime in theory and practice and how those challenges are or not successfully addressed in an enterprise regime.