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Custody model: Difference between revisions
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{{a|cass|}}How one goes about holding assets in safekeeping differs according to your jurisdiction and yea, even the legal tradition from which your system of | {{a|cass|}}How one goes about holding assets in [[safekeeping]] differs according to your [[jurisdiction]] and yea, even the legal tradition from which your basic system of law sprang. | ||
On the one hand, there are those (er, ... ''us'') crazy Commonwealth folk, all still to some degree tethered to the emotional apron strings of mother {{tag|England}}<ref>Yes, {{tag|America}}, that includes you, however much you might deny it. ''And'' you, {{tag|Australia}}.</ref> with their [[common law]] and its bonkers notions of [[precedent]], the [[Courts of chancery|separation of legal and beneficial interests]] | |||
On the other, those tiresomely sensible continentals with their romanesque belief in order, straight roads, principled-based rule-making and the primacy of legislation that hasn’t just been made up on the hoof by some guy in a horse-hair wig. Curiously they have arrived at very different models of custody of freely transferable securities. | |||
{{UK custody model}} | {{UK custody model}} | ||
{{US custody model}} | {{US custody model}} | ||
{{Continental custody model}} | {{Continental custody model}} | ||
{{sa}} | |||
*[[Courts of chancery]] | |||
*[[Doctrine of precedent]] | |||
{{ref}} | |||