Skip to main content
Article
Payment Transactions Under the EU Payment Services Directive: A U.S. Comparative Perspective
Penn State International Law Review. Volume 27, Numbers 3/4 (2009), p. 713-756.
  • Benjamin Geva, Osgoode Hall Law School of York University
Document Type
Article
Publication Date
1-1-2009
Abstract

This article endeavours to analyse the provisions of Title IV governing rights and obligations in relation to the provision and use of payment services. Analysis is particularly from a US comparative perspective. Attention will be given to Uniform Commercial Code ("UCC") Article 4A, which governs U.S. wire and other credit transfers as well as federal laws governing consumer retail payment systems. A broader but related objective of the article is the assessment of the contribution of Title IV to the harmonization of funds transfer and payment law, not only by comparison to the U.S., but also by reference to a few aspects of a national law of an EU Member State. Scope does not allow a comprehensive treatment to either aspect, particularly the latter; yet, salient issues will be addressed. The ultimate conclusion is that the Directive is a positive but inadequate step towards global and European harmonization.

Creative Commons License
Creative Commons Attribution-Noncommercial-No Derivative Works 4.0
Citation Information
Geva, Benjamin. "Payment Transactions Under the EU Payment Services Directive: A U.S. Comparative Perspective." Penn State International Law Review 27.3/4 (2009): 713-756.