Many inter-governmental and scholarly projects focus on the harmonization of the law of security interests. The aim of the paper is to present and evaluate the goals that these enterprises pursue, as well as the challenges they face. In order to do so, the paper first examines the main features of the above projects. It then proceeds to analyze, from a comparative point of view, what is similar and what is different between Western laws on security interests. Such a comparative survey sheds light, on the one hand, on the variety of legal solutions and (above all) cultural approaches one can find across Western jurisdictions. On the other hand, the comparative analysis helps highlight the methodological and substantive difficulties which, in this field, any harmonization effort (at whatever transnational level it is carried out) has to confront itself with.
- Security Interests
Available at: http://works.bepress.com/mauro_bussani/26/