Secured transactions and patterns of legal change: the contribution of comparative law

Abstract

Abstract The article analyses the many actors and initiatives that, in the last decades, have pursued the goal of worldwide harmonization of secured transaction laws, scrutinizing the achievements and the limits of these experiments. In light of such results, the article also outlines the methodological contribution that comparative law can offer to legal change in the sector of secured transactions law, by way of confronting positive law models with meta-legal elements such as culture, society, economy, law-making processes, and geopolitics.