GLOSSARY ENTRY (DERIVED FROM QUESTION BELOW) | ||||||
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07:20 May 20, 2019 |
Italian to English translations [PRO] Law/Patents - Law: Contract(s) / Procura notarile | |||||
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| Selected response from: Adrian MM. Austria | ||||
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Summary of answers provided | ||||
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4 +1 | charge or lien |
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3 | (submit) consent(ing) to the mortgaging (hypothecation) of the estate assets |
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Discussion entries: 1 | |
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charge or lien Explanation: The rest is correct. Ipoteca is often translated as charge. |
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Notes to answerer
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(submit) consent(ing) to the mortgaging (hypothecation) of the estate assets Explanation: This is a 'streamlined' answer. Mortgage IMO is the generic term for US/Can/E&W/Oz etc. (vs. Scots standard security) and, covering a multitude of scenarios, can be taken by a mortgagee/ mortgage lender over goods (chattels = conditional bills of sale by way of mortgage), ship, company shares (a mortgage in fact being a standard UK company law textbook term vs. a pledge or charge, both of the latter though used in actual legal practice), land and buildings. The difference between a mortgage, lien and charge....(non-Transatlantically) gulp! - see chapter 4. Property, vol. 1 of Oxford English Private Law) that, alas, is neither definitive, nor categoric, on this subject of 'security interests'. Charging and liening of property, as in Alison's answer, are in fact 'acceptable' verbs. Land lien (US) = a land charge in England & Wales where a lien can be taken over company shares by the company itself for non-payment of calls on shares. This can be enforced by a charging order - coincidentally, a kind of court-ordered mortgage. In the US also, a mechanic's lien can be taken over *land* for non-payment of a bill whereas, in the UK, a tradesmen's lien can taken over the work unpaid and a hotelier's lien over a non-paying guest's luggage. UK companies will have fixed charges taken by lenders over land, plant, machinery & equipment and floating charges under a registered *debenture* over the company assets 'changing from time to time in the course of business'. We will leave for now pledges and pawns, the latter as in Rod Steiger's legendary film: 'The Pawnbroker'). As a footnote by way of a rough analogy, if you know German and even if you don't, 'sich ... ( dative) unterwerfen' (to submit or subject o.s. to) corresponds to sottoporre, namely in the following case of *assenting or consenting* to a mortgage of land. Example sentence(s):
Reference: http://eng.proz.com/kudoz/german-to-english/bus-financial/42... Reference: http://www.fridaysmove.com/property-law-glossary/consent-mor... |
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