Bank Collections and Payment Transactions - A Comparative Legal Analysis (Hardcover)

This is a study of the law governing the bank-customer relationship pertaining to the disposition of funds by cheques and credit transfers, covering both paper-based and electronic payments. The work addresses, with various degrees of detail, common law, civilian, and `mixed' jurisdictions, particularly, Australia, Canada, England, France, Germany, Israel, Italy, Japan, South Africa, Switzerland and the United States. In addition to the description of the law in these jurisdictions, the book contains an in-depth analysis of the common issues and the responses to them, in light of desired policies. Accordingly, an evaluation of the various rules and proposals for reform are integral parts of the study.