Cross-border transactions of intermediated securities: a comparative analysis in substantive law and private international law
Chun, Changmin
This work aims to analyse substantive and conflict of laws rules regarding intermediated securities in a comparative way. For this purpose, it examines major jurisdictions’ rules for intermediated securities and the intermediated securities holding systems, such as the rules of the German, US, Korean, Japaneseand Swiss systems, as well as the relevant EU regimes and initiatives. Above all, it analyses the two international instruments related to intermediated securities, i.e. the Geneva Securities Convention and the Hague Securities Convention. Through a functional comparative approach based upon legal traditions of the various jurisdictions, this book gives readers theoretical and practicalinformation on intermediated securities and their national and international aspects. The first monograph comprehensively addressing legal issues arising from the Geneva Securities Convention. Issue-by-issue reform proposals for the German and Korean intermediated systems. Detailed discussion of the recently reformed intermediated systems, the Japanese and Swiss systems. Clear figures for better understanding of the legal issues. Numerous, in-depth references on the relevant issues. Practical information for practitioners and participants in the financial industry.
- ISBN: 978-3-642-27852-5
- Editorial: Springer Berlin Heidelberg
- Encuadernacion: Cartoné
- Páginas: 500
- Fecha Publicación: 30/04/2012
- Nº Volúmenes: 1
- Idioma: Inglés