Micheler analyses the German, Austrian and English law of
securities, addressing the rules governing transfers of securities,
including unauthorised transfers, equities arising out of defective
issues, and the holding of securities through intermediaries. The
book presents an account of the current English, German and
Austrian regimes. It has been written with a view to explaining the
German and Austrian regime to readers with a common law background
and to explaining the English regime to readers with a civil law
background. Micheler also aims to determine whether globalisation
will cause the two different approaches to converge. It concludes
that the respective rules in all three jurisdictions have
historically evolved consistently with incumbent legal doctrine.
This pattern of change is likely to continue. Convergence will
occur on a functional rather than doctrinal level. Moreover, recent
reform initiatives advanced by the UNIDROIT and the EU will lead to
functional rather than doctrinal convergence.
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