This Chapter provides a comparative analysis of English, Swedish and US law in relation to the questions discussed in this book. It summarises the main problems as well as the main conclusions, and provides some recommendations on how to structure a well-balanced and functional property and security law system.
The analysis, which is made with the aim of identifying possible solutions, supports the main argument of the book that due to the developments of the financial markets and the securities holding systems, securities as assets have outgrown the existing property law structures. The examination also shows that the problems are predominantly the same in all jurisdictions covered by the study.
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© 2009 Springer-Verlag Berlin Heidelberg
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(2009). Property Rights in Securities and the Doctrine of Specificity: A Comparative Analysis with an Outlook De Lege Ferenda. In: Johansson, E. (eds) Property Rights in Investment Securities and the Doctrine of Specificity. Springer, Berlin, Heidelberg. https://doi.org/10.1007/978-3-540-85904-8_9
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DOI: https://doi.org/10.1007/978-3-540-85904-8_9
Publisher Name: Springer, Berlin, Heidelberg
Print ISBN: 978-3-540-85903-1
Online ISBN: 978-3-540-85904-8
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