Abstract
Since 2002, the Financial Collateral Directive (“FCD”) has provided European Union Member States with a common framework for the provision of financial collateral as security.This paper considers the impact which the FCD has had in Irish credit and security law. In particular examines the “control” test which the Directive has introduced into perfection law in Europe and compares this test with a similar measure found in Articles 8 and 9 of the Uniform Commercial Code in the United States.
Original language | English |
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Pages (from-to) | 73 |
Journal | Commercial Law Practitioner |
Volume | 17 |
Issue number | 4 |
Publication status | Published (in print/issue) - 28 Apr 2010 |