Introduction
The law applicable to third-party effects of assignments of claims: the U.N. Convention and the E.U. Commission Proposal compared
BeiträgeSpyridon V. Bazinas11The author is grateful to Edwin E. Smith, Partner, Morgan Lewis (Boston/New York) for helpful comments on an earlier version of this article. The author is solely responsible though for the final content of this article.ZFR 2019/99ZFR 2019, 217 Heft 5 v. 29.5.2019
Inhalt
- 1. The importance of a coordinated approach
- 2. Scope of application
- 3. Matters covered
- 4. Applicable law: main rule
- 5. Applicable law: special rule for the assignment of claims arising from deposit accounts and financial instruments
- 6. Applicable law: special choice-of-law rule for the assignment of receivables in securitization transactions
- 7. Applicable law: special rule for assignments of claims with respect to which the matters governed may be referred to more than one law
- 8. Public policy and mandatory rules
- 9. Conclusions
