Beschreibung
This doctoral thesis, written at the Fribourg Faculty of Law, examines floating charges and non-possessory securities over movables across five legal systems, considering international harmonization by UNCITRAL. It explores financing opportunities for business, particularly in production and manufacturing. It compares these securities, analyzing their requirements and implementation in common and civil law jurisdictions, contrasting American and English approaches, and examining Swiss, French, and Turkish perspectives. It investigates third-party effectiveness and priority regimes among creditors, offering practical guidelines on the risks SMEs and lenders face in non-possessory secured transactions involving movable assets.