The evolution of partnership forms is stimulated by powerful economic forces that can lead to widespread prosperity and wealth creation for a society. Given the importance of closely held firms in the United States and Europe, "The Evolution of Legal Business Forms in Europe and the United States argues that partnership law should trouble itself less with historical and descriptive arguments about the legal rules and structure of the partnership form and focus much more on the new analytical apparatus of the economics of organizational form as well the fundamental economic learning that informs the debates on limited liability, partnership rules regarding management and control, conflict resolution and fiduciary duties. Introducing and extending the best available theories from law and economics, particularly those from the theory of the firm, This book's analysis demonstrates that the patterns of European partnership law and is recent history are best understood from an economic and comparative law perspective. By examining the economic theories of the firm and the economics of organization choice, "The Evolution of Legal Business Forms in Europe and the United States conceives partnership-type business forms as contractual entities. The key feature of the modern partnership form is that partners have significant flexibility and power to limit their liability, transfer all of their rights, and to freely exit the firm. Another key feature of partnership law is the insight that lawmakers should provide the rules and enforcement mechanisms to regulate the important relationships within the partnership. This book applies an efficiency test to determine which sets of default rules arelikely to resolve the main problems in partnerships. Having identified partnership law with the economic theory of organization, "The Evolution of Legal business Forms in Europe and the United States then goes to argue that most of partnership law is directed at offering bundles of legal rules for different types of firms. Lawmakers should promote partnership rules that attract investors and can be expected to be efficient if they allow entrepreneurs to freely select the bundle of rules that best match their priorities. In a modern vision of partnership law, lawmakers promote economic welfare through creating non-mandatory rules that allow multiple businesses to switch to a favorable business form without significant costs. Jurisdictions plagued by falling incorporations and low levels of small and medium business activity, should abandon the mandatory and standardized framework and the 'lock in' effect that it promotes, and focus on the mechanisms of legal evolution and rules that tend to mimic the market. This innovation work will have ramifications felt across European jurisdictions, and will be debated by a large audience of policymakers and academic lawyers involved in law reform. Moreover, the book will receive serious attention from students of law and economics, as well as practising lawyers involved in resolving complex issues of organizational law.

Due to the nature of the arbitration process, provisional measures - especially interim protection of rights - tend to play a disproportionate role in international commercial arbitrations. Indeed, the need to clearly define such measures often constitutes the major stumbling block on the path to an effective resolution of a commercial dispute. This concise but enormously useful volume offers practitioners the information and advice they need to overcome this obstacle in the best possible way every time. The author covers all the relevant avenues of research and practice, from an overview of the concept of provisional measures to an in-depth analysis of the weight and enforceability of such measures. Along the way the treatment covers such crucial topics and issues as the following: scholarly analysis of the problems and uncertainties surrounding provisional measures, and their solutions in light of arbitral and judicial practice; the complex interaction of historical prejudices, political will, and business needs that impact the usefulness of provisional measures; choice of forum to seek provisional measures and the problems associated with such choice; complementary mechanisms to arbitration for interim protection of rights; standards of principles and procedures for the grant of provisional measures; and a comprehensive review of the arbitrators' power to grant provisional measures and court assistance to arbitration. The presentation examines, compares, and analyses seventy sets of arbitration rules on provisional measures (including the arbitration rules of the ICC, AAA, and LCIA), all of the major state laws on commercial arbitration, and detailed analyses of numerous ICC and AAA awards, most of which have not been published before. This new and fully researched book fulfils and important need for user-friendly and complete practical coverage of provisional measures in international commercial arbitration. It will be of great value to corporate counsel, international lawyers, and business people, as well as to students of dispute resolution.

INTRODUCTION George Bernard Shaw wrote - 'when a stupid man is doing something he is ashamed 1 of, he always declares that it is his duty. ' Years earlier La Rochefoucauld noted, 'hypocrisy is the homage vice pays to virtue. ' But whether stupid or wise, men are not just hypocritical; they are often honestly unsure where their duty lies. This is one of the main reasons for the creation of rules and exceptions to these rules. This book looks at the law of copyright, exceptions to copyright, which apply to Higher Education Institutions (hereinafter HEIs) and the position of the academic author in relation to the reward or incentive system. As such, the book further considers whether academic authors within HEIs are fairly remunerated for their academic contri- tions by the system of copyright collecting societies; and if not, whether alternative models exist to remunerate the academic author fairly. 2 HEIs include universities and other institutions such as colleges and vocational institutions, which award academic degrees including diplomas. This book will focus solely on the university sector of HEIs in the UK. In exploring the two broad subject areas of HEIs and Copyright Collecting Societies, a large variety of issues can be isolated for specific consideration.

A comprehensive and accessible guide in Business Law that is also suitable for non-students. Business Law, 9th edition by Ewan MacIntyre is a comprehensive guide to the subject, aiming to help you gain a deeper understanding of the legal principles that apply to business. This text is ideal for students who study Business Law in a wide variety of courses, such as business or accountancy-related, as well as professional or post-graduate courses that require a thorough grounding in the specific field. The book covers most areas in an academically rigorous way but is written in a language that is straightforward and easy to understand. This edition provides an in-depth, up-to-date treatment of the law, with significant updates in many cases that reflect changes in the legislation - especially EU law. Key features include: Comprehensive content: covers a wide variety of business law subjects, including Employment, Consumer Credit, and Intellectual Property. A clear outline: helps you organise your studying of the topics efficiently and fully grasp all aspects of the subject. Key points and tasks: encourage you to apply what you have learned to business situations. Multiple-choice and in-depth problem questions: allow you to consolidate your understanding and learning of the topics. Easy to read and with a range of references to support your understanding of the subject, this textbook offers full coverage of the theory and practical applications in Business Law.

This book is the first comprehensive study on the legal aspects of trustmarks: labels or visual representations indicating that a product, process, or service conforms to specific quality characteristics. Trustmark Organisations (TMOs) are independent parties which provide e-merchants with such trustmarks. Security, privacy, and business practice are three areas in which trustmarks play an important role. TMOs will issue a trustmark to e-merchants only if they have demonstrated that they conform to the policy of TMOs regarding security and/or privacy and/or business practice. E-merchants hope that, by displaying the trustmark on their websites, e-consumers will trust their certified practice and be more likely to divulge their personal data and transact with them. Past research has focused on the economic aspects of trustmarks. However, there are no legal studies to be found on the matter. This book aims to fill that gap. It describes the pros and cons of trustmarks for e-economy, e-society and e-policy, assesses TMOs' practice, and focuses on TMOs' liability. The book is valuable reading for academics and practitioners in the IT and ICT field and for all those involved in e-commerce both at a European and global level. Dr Paolo Balboni is currently an Associate at Baker & McKenzie, IT/Communications and Intellectual Property Department, in the Milan office in Italy. He is also a Research Associate at Tilburg University, both at the Tilburg Institute for Law Technology, and Society TILT and at the Tilburg Institute for Interdisciplinary Studies and Conflict Resolution Systems TISCO. This is Volume 17 in the Information Technology and Law (IT&Law) Series

Women, Business and the Law 2022 is the eighth in a series of annual studies measuring the laws and regulations that affect women's economic opportunity in 190 economies. The project presents eight indicators structured around women's interactions with the law as they move through their careers: Mobility, Workplace, Pay, Marriage, Parenthood, Entrepreneurship, Assets, and Pension. Amid a global pandemic that threatens progress toward gender equality, 'Women, Business and the Law 2022' identifies barriers to women's economic participation and encourages reform of discriminatory laws. This year, the study also includes pilot research related to childcare and implementation of the law. By examining the economic decisions women make throughout their working lives, as well as the pace of reform over the past 50 years, Women, Business and the Law makes an important contribution to research and policy discussions about the state of women's economic empowerment. The indicators build evidence of the critical relationship between legal gender equality and women's employment and entrepreneurship. Data in 'Women, Business and the Law 2022' are current as of October 1, 2021.

Perspectives on the Law of Partnership in South Africa examines the most problematic issues in the law of partnership. It investigates specific issues in the area of partnership law, painting a broader picture of all the other relevant areas involved. In following a `perspectives' approach - presenting a historical and a comparative perspective - the book offers a detailed consideration of complex areas of partnership law while at the same time exploring the law in general. Topics discussed range from the history and development of partnership law to perennial classical favourites such as the leonine partnership, the triple contract and universal partnership proper, all three of which contributed to the delineation of the partnership concept. Aspects of the law in general that are discussed in detail include: Legal status and its attendant entity and aggregate theories, representation and mutual mandate, partnerships en commandite, anonymous, limited and limited liability partnerships, the removal of the limit on the number of partners, partnership sequestration, the dual priorities rule. Perspectives on the Law of Partnership in South Africa is offered as a scholarly book for the subject specialist with the expectation that it will also invigorate interest in and advance research on the law of partnership.

This book is both a repertory guide to the Convention on International Civil Aviation (Chicago Convention) as well as a legal analysis of the provisions of the treaty. It traces action taken by the ICAO Assembly and the Council in the implementation of the Convention from the first ICAO Assembly in 1947 until 2012. Above all, the book offers a commentary on the functional and moral fabric of the Chicago Convention, which is not only a multilateral legal instrument that sets out basic principles of air navigation and air transport, but also serves as a moral compass that brings the people of the world together.

The teleological nature of the Chicago Convention is reflected from the outset from its Preamble which sets the tone and philosophy of the Convention that aviation builds friendship and understanding among all people, to its technical provisions that range from rules of the air to landing at airports and customs and immigration procedures. The book effectively demonstrates the Aristotelian principle that rules make people good by forming habits in them. Standardization, or in other words, compliance, is the driver of the Convention that keeps aviation safe, regular, efficient and economical. To that end, this book traces and details the sustained relevance of the Chicago Convention and the efforts of ICAO and the international aviation community towards keeping air transport on track and ready for its future exponential growth, both in letter and in spirit. "

This book contains a series of studies of the regulation under English law of the range of business organisational structures available to entrepreneurs. It analyses the commonest of these structures,including limited companies (public and private), groups of companies, privatised enterprises, and partnerships, as well as the more specialised forms such as industrial and provident societies, banks, building societies, insurance companies, joint ventures, franchise agreements, limited partnerships and overseas companies. Set within the context of a period of considerable actual and proposed legal change, the contributions (from recognised authorities in their respective fields) analyse the broad regulatory structure adopted for each of the above business forms, outline the changing patterns of regulation and consider likely future developments. Several broad themes run through the work, including the relationship between the economic desirability of facilitating enterprise and the need to regulate against possible abuse; stakeholder protection; pursuit of risk management strategies and the implications of European harmonisation in the business sector.

This book presents a hotly debated issue concerning the ownership of trust property in China. The book describes various conventional interpretations of Chinese Trust Law submitted by legal scholars and compares diverse approaches regarding the ownership of trust property provided by jurisdictions globally. The book does not directly answer the question "Who is the owner of trust property in China?" Instead, using a social capital perspective, it develops a more practical perspective to explain why Chinese trust business has grown rapidly even in lack of legal certainty regarding the location of ownership of trust property. The book also further predicts under what conditions is the time ripe to clarify the location of the ownership of trust property in China. By employing those sociological concepts often used to depict and analyze society, this book outlines the structure of the Chinese trust business and related social relations in different stages, i.e., the current rapid development stage, and the possible transitional stage in the near future. The focus is on how the social network structure affects the behavior of actors (such as the settlor, the trustee, and the beneficiaries, and/or their potential candidates) within the relevant section of Chinese society. The book provides readers with an intensive analysis of the impacts of historical, cultural, and social elements on the legislation and development of trust law in China. It will appeal both to lawyers interested in the Chinese trust business and to comparative law researchers and social scientists.

This volume presents national reports describing the legal instruments that are available to prevent the payment of bribes for acquiring contracts. Anti-corruption is one of the preeminent issues in the modern global commercial order and is tackled with the help of criminal law and contract law in different ways in different countries. The reports included in this volume, from very diverse parts of the world, represent a unique and rich compilation of court decisions, doctrinal discussions and a pool of suggested solutions. The central theme is the enforceability of three problematic types of contracts: the bribe agreement, whereby a bribe payer promises the agent of his business partner a personal benefit in exchange for favourable contract terms; the agreement between a bribe payer and an intermediary (a "bribe merchant"), where the latter offers his expertise to help funnel bribes to agents of the business partner; and finally, the contract between the bribe payer and his business partner which was obtained by means of bribery. The analysis is tailored toward commercial contracts, which can also include contracts with state-owned enterprises. The examination and comparison of international and national initiatives included in this volume advance the discussion on the most appropriate remedies in corruption cases, and show how to get past the boundaries of criminal, private and contract law.

The Development of Commercial Law in Sweden and Finland provides a broad perspective on recent research into the history of North European commercial law in a comparative and international framework. The book brings together themes that have previously been considered largely from a national perspective. Despite Sweden's and Finland's peripheral locations in Europe, global legal phenomena took place there as well. These countries were at the crossroads of cultures and commercial interests, allowing us to re-examine them as lively laboratories for commercial laws and practices rather than dismissing them as a negligible periphery. The importance of trade and international transactions cannot be disclaimed, but the book also emphasizes the resilient nature of commercial law. Contributors are: Dave De ruysscher, Stefania Gialdroni, Ulla Ijas, Marko Lamberg, Heikki Pihlajamaki, Jussi Sallila, and Katja Tikka.

This book discusses the role of private law as an instrument to produce financial and social inclusion in a context characterised by the redefinition of the role of the State and by the financialisation of society. By depicting the political and economic developments behind the popular idea of financial inclusion, the book deconstructs that notion, illustrating the existence and interaction of different discourses surrounding it. The book further traces the evolution of inclusion, specifically in the European context, and thus moves on to analyse the legal rules which are most relevant for the purposes of bringing about the financialisation of the citizen. Hence, the author focuses more on four highly topical areas: access to a bank account, access to credit, over indebtedness, and financial education. Adopting a critical and inter-disciplinary approach, The Financialisation of the Citizen takes the reader through a top-down journey starting from the political economy of financialisation, to the law and policy of the European Union, and finally to more specific private law rules.

This book focuses on the impact of technology on taxation and deals with the broad effect of technology on diverse taxation systems. It addresses the highly relevant eTax issue and argues that while VAT may not be the ultimate solution with regard to taxing electronic commerce, it can be demonstrated to be the most effective solution to date. The book analyzes the application and the effectiveness of traditional income tax principles in contradistinction to VAT principles. Taking into account rapidly ameliorating technology, the book next assesses the compatibility between electronic commerce and diverse systems of taxation. Using case studies of Amazon.com and Second Life as well as additional practical examples, the book demonstrates the effectiveness of VAT in respect of electronic commerce and ameliorating technology in the incalculable and borderless realm of cyberspace.

This book adds to the debate on the effects of covenants on third-party creditors (externalities), which have recently become a focus of discussion in the contexts of bankruptcy law, corporate law and corporate governance. The general thrust of the debate is that negative effects on third-party creditors predominate because banks act in their own self-interest. After systematising the debated potential positive and negative externalities of covenants, the book empirically examines these externalities: It investigates the banks' factual conduct and its effects on third-party creditors in Germany and the US. The study's most significant outcome is that it disproves the assumption that banks disregard third-party creditors' interests. These findings are then interpreted with the tools of economic analysis; particularly, with the concept of common pool resources (CPRs). Around the aggregated value of the debtor company's asset pool (as CPR) exists an n-person prisoner's dilemma between banks and third-party creditors: No creditor knows when and under what conditions the other creditor will appropriate funds from the debtor company's asset pool. This coordination problem is traditionally addressed by means of bankruptcy law and collaterals. However, the incentive structure that surrounds the bilateral private governance system created by covenants and an event of default clause (a CPR private governance system) is found to also be capable of tackling this problem. Moreover, the interaction between the different regulation spheres - bankruptcy law, collateral and the CPR private governance system has important implications for both the aforementioned discussions as well as the legal treatment of covenants and event of default clauses. Covenants alone cannot be seen as an alternative to institutional regulation; the complete CPR private governance system and its interaction with institutional regulation must also be taken into consideration. In addition, their function must first find more acceptance and respect in the legal treatment of covenants and event of default clauses: The CPR private governance system fills a gap in the regulation of the tragedy of the commons by bankruptcy law and collateral. This has particularly important implications for the German 138 BGB, 826 BGB and ad hoc duties to disclose insider information.

What began as a standoff between competing steamship entrepreneurs ended as one of the Supreme Court's most significant cases. Gibbons v. Ogden in 1824 brought into sharp relief the ongoing tug-of-war for power between individual states and the federal government. By applying the Commerce Clause of the Constitution, the Court set a key precedent for federal authority. But, behind the scenes, the ""Steamboat Case"" also demonstrated Chief Justice John Marshall's instrumental role as mediator on the bench. Untangling the issues and the arguments in Gibbons, Herbert Johnson reveals the lasting impact of this landmark case on both commerce in the Early Republic and the understanding and growth of federal power during the last 200 years. Johnson brings the case's protagonists--including Marshall and Daniel Webster--vividly to life and deftly illuminates its key aspects: the ambiguity of the Court's judgment; Justice William Johnson's nationalist-oriented concurring opinion; Marshall's avoidance of such key issues as the role of the dormant commerce clause and the relationship of foreign trade, interstate commerce, and diplomatic relations; and Marshall's failure to address patents and state monopolies. Perhaps most significant, the author challenges the traditional view that Gibbons established that the Constitution bestowed upon Congress an exclusive power to regulate interstate commerce. Drawing on recent research into the early Court, Johnson shows how Gibbons provides a salient example of Marshall's ability to gain agreement despite severe differences among his colleagues. No longer surrounded by fellow Federalists on the bench, Marshall mustered all of his managerial skills to achieve consensus, and his opinion for the Court reflected the concessions and agreements that he engineered to achieve near unanimity in a decision that favored federal power without establishing a definitive endorsement of it. Johnson shows that the outcome of this case was a key moment in the economic history of the nation, heralding the expansion of entrepreneurship and technology while justifying federal primacy in the regulation of commerce. Concise and ideally suited for the classroom, his study not only provides new insight into this landmark case but also attests to its significance in the working of the early Court. This book is part of the Landmark Law Cases and American Society series.

This book contains the papers written for the seventh volume in the Oxford-Norton Rose Law Colloquium Series, which was held in St Hugh's College, Oxford, on 22nd-23rd September, 2006. As with past colloquia, this brought together practitioners (solicitors, barristers and Judges) and academics to examine and discuss an area of commercial law. The belief underpinning all the colloquia has been that the sharing of views on central topics of commercial law can only work to the mutual advantage of both academics and practitioners. The topic chosen this year was Contract Terms which is a topic of everyday importance to all commercial lawyers. It is also an area in which academics have become increasingly interested in recent years.
The book begins with an introduction by the editors which draws out the central features of the discussions at the colloquium. It is followed by an introductory practitioners' perspective written by Richard Calnan of Norton Rose.
The colloquium papers have then been divided into three main sections. The first on 'Construction and Interpretation' comprises the papers written by Gerard McMeel, Edwin Peel, Andrew Burrows, Robert Stevens and Stefan Vogenauer. The second on 'Legislative Control of Unfair Terms' has papers by Elizabeth MacDonald, Susan Bright and Hugh Beale. The third on 'Issues Related to Particular Types of Term' looks at entire agreement clauses, termination clauses, force majeure clauses, retention of title clauses and choice of law clauses. This third section contains chapters written by John Cartwright, Ewan McKendrick, Simon Whittaker, Louise Gullifer and Adrian Briggs.
The papers have all been written by eminent academics andtogether they provide a stimulating and up-to-date examination of Contract Terms. The book will be essential reading for all practitioners involved in drafting contracts or in commercial litigation, commercial barristers, and academics interested in contract and commercial law. The foreword has been written by the senior Law Lord, Lord Bingham of Cornhill.

What began as a standoff between competing steamship entrepreneurs ended as one of the Supreme Court's most significant cases. Gibbons v. Ogden in 1824 brought into sharp relief the ongoing tug-of-war for power between individual states and the federal government. By applying the Commerce Clause of the Constitution, the Court set a key precedent for federal authority. But, behind the scenes, the ""Steamboat Case"" also demonstrated Chief Justice John Marshall's instrumental role as mediator on the bench. Untangling the issues and the arguments in Gibbons, Herbert Johnson reveals the lasting impact of this landmark case on both commerce in the Early Republic and the understanding and growth of federal power during the last 200 years. Johnson brings the case's protagonists--including Marshall and Daniel Webster--vividly to life and deftly illuminates its key aspects: the ambiguity of the Court's judgment; Justice William Johnson's nationalist-oriented concurring opinion; Marshall's avoidance of such key issues as the role of the dormant commerce clause and the relationship of foreign trade, interstate commerce, and diplomatic relations; and Marshall's failure to address patents and state monopolies. Perhaps most significant, the author challenges the traditional view that Gibbons established that the Constitution bestowed upon Congress an exclusive power to regulate interstate commerce. Drawing on recent research into the early Court, Johnson shows how Gibbons provides a salient example of Marshall's ability to gain agreement despite severe differences among his colleagues. No longer surrounded by fellow Federalists on the bench, Marshall mustered all of his managerial skills to achieve consensus, and his opinion for the Court reflected the concessions and agreements that he engineered to achieve near unanimity in a decision that favored federal power without establishing a definitive endorsement of it. Johnson shows that the outcome of this case was a key moment in the economic history of the nation, heralding the expansion of entrepreneurship and technology while justifying federal primacy in the regulation of commerce. Concise and ideally suited for the classroom, his study not only provides new insight into this landmark case but also attests to its significance in the working of the early Court. This book is part of the Landmark Law Cases and American Society series.

Recent case-law and legislation in European company and insolvency law have significantly furthered the integration of European business regulation. In particular, the case-law of the European Court of Justice and the introduction of the EU Insolvency Regulation have provided the stimulus for current reforms in various jurisdictions in the fields of insolvency and financial law. The UK, for instance, has adopted the Enterprise Act in 2002, designed, inter alia, to enhance enterprise and to strengthen the UK's approach to bankruptcy and corporate rescue. In a similar vein, recent reform in France has modernized French insolvency law and has even introduced a tool similar to the successful English 'company voluntary arrangement' (CVA). This book provides a collection of studies by some of the leading English and French experts today, analyzing current perspectives of insolvency and financial law in Europe, both on the national level as well as on the European level.

This unique text deals with the most important legal areas for e-commerce related business in most of the member states in Europe as well as the USA. In doing so the text takes into consideration the national law of the following countries: Belgium, France, Germany, Great Britain, Italy, Netherlands, Norway, Spain, Switzerland, and the USA. Topics that are dealt with include: contract law, consumer protection, intellectual property law, unfair competition, antitrust law, liability of providers, money transactions, privacy and data protection. The country-specific contributions follow a questionnaire which can be found in the beginning. The uniform structure of each contribution enables the reader to quickly find an answer to a legal question. All contributions have been written by experts from each member state.

Private International Law (PIL) in Europe is marked by fragmentation and complexity. At EU level, thus far six separate regulations determine the applicable law in different fields of the internal market (e.g. contractual/non-contractual obligations, divorAce, succession). While their scope and structure are similar, they do not offer a coherent picture of EU PIL. Moreover, the regulations do not address certain issues at all. To make matters even more complicated, national PIL rules of the Member States apply for areas not yet covered by EU PIL. This state of affairs has sparked a debate on whether a set of general rules or perhaps a special regulation (''Rome '') could help to reduce this complexity. But no common position, even on the scope of such a set of rules, has been reached yet.This book begins by taking a step back. It systematically and exhaustively analyses existing PIL rules and issues in EU and national legislation, covering all EU Member States in the process. It then demonstrates that the characteristics of PIL themselves imply a framework for ''general issues'' independently from language, codification or underlying legal tradition. This is largely due to the common elements of PIL rules, i.e. subject matter, connecting factor, and governing law. Taking this further, the book concludes with possible implications for the EU from a law and policy perspective.

This book offers a valuable guide to one of the most challenging areas of commercial law, now frequently referred to as secured transactions, with a focus on Nigerian, Canadian and United States perspectives. A debtor's ability to provide collateral influences not only the cost of the money borrowed, but also in many cases, whether secured lenders are willing to offer credit at all. The book proposes that increasing access to, and indeed, lowering the cost of credit could tremendously boost economic development, while at the same time arguing that this would best be achieved if the legal framework for secured transactions in Nigeria, and of course, any other country with similar experiences, were designed to allow the use of personal property and fixtures to secure credit. Similarly, the creation, priority, perfection, and enforcement of security interests in personal property should be simplified and supported by a framework that ensures that neither the interests of secured lenders nor debtors are hampered, so as to guarantee the continuous availability of affordable credit as well as debtors' willingness to borrow and do business. The book further argues that in addition to the obvious preference for real property over personal property by secured lenders due to the unreformed secured-transactions legal framework in Nigeria, its compartmentalized nature has also resulted in unpredictability in commerce and the concomitant effects of poor access to credit. Through the comparative research conducted in this book utilizing the UCC Article 9 and Ontario PPSA as benchmarks, the author provides reformers with a repository of tested secured-transactions law solutions, which law reformers in the Commonwealth countries in Africa and beyond, as well as the business community will find valuable in dealing with issues that stem from secured transactions.