Abstract
This paper discusses the three legal regimes which furnish models of laws designed to promote the use of moveables and intangibles to finance small businesses. One is the nantissement de fonds de commerce, a device used in the French law which creates a mortgage on a business - or at least some parts of it. The second is the registered charge of the European Bank's Model Law on Secured Transactions, which is modeled in large part on the English financing device called a floating charge. The third is the North American security interest used in Article 9 of the Uniform Commercial Code in the U.S., and in the Personal Property Security Acts in Canada.
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