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一、日本版ABL——以何作为目的物的担保方式在日本,“ABL”这一概念是在本世纪初开始被使用的。ABL这一概念来自美国的Asset Based Lending(ABL);参照《美国统一商法典》(UCC)第九编中的动产债权担保法规的同时,有意识地将对应美国的实际交易情况的美国版ABL和需要在日本确立起来的日本版ABL进行区分,是日本早期的对于ABL研究的主流论调。日本版ABL可以看作是美国版的ABL(commercial finance的一种)的对立概念,通过与美国的现金流动型金融
First, the Japanese version ABL - what to take as a means of security in Japan In Japan, the concept of “ABL” was used at the beginning of this century. The concept of ABL comes from Asset Based Lending (ABL) in the United States. While referring to the law on real property debt guarantees in Part 9 of the United States Uniform Commercial Code (UCC), the concept of ABL is consciously linked to the US version of ABL, which corresponds to actual U.S. transactions The need to distinguish between the Japanese version of ABL, which is established in Japan, is the mainstream Japanese argument for ABL research in the early days of Japan. The Japanese version of ABL can be seen as the American version of ABL (a commercial finance) the opposite concept, through the United States and cash-flow finance