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The Holding and Transfer of Interests in Securities in England and Japan: Compared with the Holding and Transfer of Funds
Abstract
This chapter compares account-based securities settlement systems with payment systems in which funds are transferred through bank accounts in England and Japan and examines a desirable securities system to harmonize the relevant countries’ jurisprudence considering US securities system and relevant international trends. It argues that there should be two broad areas of similarity in both systems; compartmentalization of a legal relationship between related parties and the method of transfer of securities and funds. It also argues, however, that, due to the differences in the legal nature of both financial assets, there are some differences between both systems in order to response intermediary risk. The purpose of this chapter is not only to propose that similar legal issues in both systems should be resolved in same ways as much as possible, but also to distinguish issues which could be resolved in commercial law from issues which should be resolved in the field of regulations by financial authorities in securities system.
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