The Institution of Security Agent: A Comparative Study of Polish and French Laws - European Business Law Review View The Institution of Security Agent: A Comparative Study of Polish and French Laws by - European Business Law Review The Institution of Security Agent: A Comparative Study of Polish and French Laws 33 7

In many continental legal systems it was often problematic to grant a security right to an entity separate from the holder(s) of the secured receivables. Such arrangement was especially desired by the parties in complex lending structures with many creditors. To solve this problem various legal solutions have been created in different countries. In Poland and in France the special institution of a security agent has been introduced. Aim of this article is to compare those two regulations. The conclusion is that the French provisions better deals with the challenges posed by the entity separation problem.

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