Preface

Summary

The law relating to security rights in movable property is one of the areas where the diversity of national laws is of special practical importance. As a consequence of the universally accepted rule of private international law, the lex rei sitae, two or more different laws have to be applied consecutively to a single transaction, if collateral is moved across borders. Because such movement is at the heart of the idea of a Common Market it comes as no surprise that the first project which emerged from the property law group of the Common Core was dedicated to security rights in movables.

Like all volumes in this series, this book is truly a collective scholarly enterprise. I am grateful to all contributors who prepared their reports and essays and discussed them at various annual meetings in Trento. Three of them, Michele Graziadei, George Gretton and Cornelius van der Merwe, were of special assistance in compiling the reports, drafting the comparative observations and finding a common terminology. Special thanks are due to Matthias Storme, who drafted the first version of the questionnaire and acted as editor in the beginning.

The editor and those contributors who are not native English speakers owe a great debt of gratitude to Alec Brown of the English Bar, who corrected the style of the texts. Without his dedication and diligence, the book might not have seen the light of day. All remaining errors are, however, the respective authors’ responsibility.