Floating Security Interest - Comparative Analysis of the US, English, and Croatian Approaches

The author compares floating security interest under three jurisdictions: US, English and Croatian. The article introduces the genesis of the floating security interest, its creation, and, most importantly, the priority rules under these three jurisdictions according to which floating security interests will be ranked among secured claims in enforcement or bankruptcy proceedings. Croatia has introduced floating security interest by the Law on the Registry of Court and Public-Notary Security Interests on Movables and Rights in 2006. In this article it will be shown how the introduction of this new security device affected the German model of the secured transactions which Croatia initially adopted and which still prevails in its legal system.