摘要：There have been several articles which have compared the current Australian approach, using charges, and the North American approach, using security interests; but they have all been prepared by non-North American authors, and some do not have a full perspective of the effects of UCC Article 9. In addition, the Commonwealth Attorney General’s office seems to base its current evaluation of the North American approach on a single quotation from a book published in 1964. Both UCC Article 9 and the United States insolvency laws have been redrafted since that time of twenty-eight years ago, so perhaps it is useful for an American explanation of current American law. Thus, this paper will outline the significant aspects of the North American ’security interest’ approach to secured financing.
