The EU financial collateral directive: the distinguishing features of a security financial collateral arrangement?

Abstract The first part of this article considers whether a system-neutral meaning title transfer financial collateral arrangement (TTFSA) can be identified in the EU Collateral Directive. This looks at similar issue—it security (SFCA) Financial Arrangement It is argued that definition SFCA Directive based on assumption there specific organizing principle or concept makes it easy to clearly identify, and demarcate, SFCAs from other types arrangements (particularly TTFCAs). While fits well within model Civil law systems, which may have clear ‘security right’, does not fit common law. arguments call for careful approach