The English trust is a unique legal device whose origin has been the source of much debate among legal scholars. There are three theories concerning the origin of the English trust: the Roman, Germanic, and Islamic. Until the nineteenth century, it was believed the trust was modeled on the Roman fideicommissum. By the nineteenth century, the accepted theory was that the trust was modeled on the Salic law of the Salmannus. The latest theory is that the trust is based on the Islamic waqf. Charles E. Rounds, Jr. elaborates in Section 8.37 of Loring and Rounds: A Trustee’s Handbook (2012), which section is reproduced below.