Commercial Trusts in European Private Law

Michele Graziadei · Ugo Mattei · Lionel Smith

2005년 11월 · Cambridge University Press

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In European legal systems, a variety of approaches to trust and relationships of trust meet the universal professionalisation of asset management services. This book explores that interface in order to seek a better understanding of the legal regulation of the entrustment of wealth. Within the methodology of the Common Core of European Private Law, the book sets out cases on the establishment and termination of management relationships, obligations of loyalty and of professionalism, and the choice of law. More specialized cases address collective investment, collective secured lending, pension funds, and securitisation. Reports on these cases from fifteen jurisdictions of the European Union tackle fundamental problems of trust law and show which legal techniques are deployed to solve them across Europe. In addition to a much-needed comparative treatment of the subject, the book discusses the scholarly setting for the issues and gives guidance on the terminology in the evolving European scene.

저자 정보

Professor of Comparative Private Law, Facolta di giurisprudenza, Universita del Piemonte orientale.

Professore Ordinario di Diritto Civile, Universita di Torino; Alfred and Hanna Fromm Professor of International and Comparative Law, University of California, Hastings College of Law.

James McGill Professor of Law, Faculty of Law and Institute of Comparative Law, McGill University.