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Is More Always Better? Are Multiple Forms of General Security Agreement Necessary in Every Cross-Border Financing?

U.S. and Canadian Forms of General Security Agreement. It is not uncommon in cross-border financing transactions to have multiple U.S. and Canadian entities as borrowers or guarantors. In these transactions, there are often...more

A Cross-Border View of Purchase Money Security Interests Under the UCC and the PPSA

In a recent blog entry, I discussed the divergent treatment of name changes and other post filing or registration events under the Uniform Commercial Code (UCC) and the Personal Property Security Act (PPSA). This blog entry...more

The Cross-Border Perspective: Name Changes and Other Post-Filing or Registration Events Under the UCC and the PPSA

We are U.S. lawyers and don’t practice Canadian law. But we seize every occasion that we have to deepen our understanding of the differences between U.S. and Canadian law. Why? Because understanding the differences allows us...more

More Than Just A Passing Interest: Ensuring Your Rights Are Secured Under The PPSA

If you are a holder of a security interest in personal property (including patents) you will need to record the interest on the Personal Properties Security Register (PPSR) before 31 January 2014, otherwise you may lose the...more

Don't Lose Your Priority in 2014 – Australian Transitional Perfection of Security Interests to Expire!

Many companies doing business in Australia have been caught unaware of an impending impactof the Personal Property Securities Act 2009 (Cth) (PPSA). In considering the effect of the PPSA on your business, it is critical that...more

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