Glossary entry (derived from question below)
German term or phrase:
Pfandrecht
English translation:
(gen) security interest; (US land) lien; (BrE land) charge
German term
Pfandrecht
Is Pfandrecht "pledge" or "lien"? I am not sure of the differences in English to be honest. Thanks for the help!
| 4 +1 | (gen) security interest; (US land) lien; (BrE land) charge |
Adrian MM. (X)
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Apr 22, 2016 19:14: AllegroTrans changed "Level" from "Non-PRO" to "PRO"
Apr 24, 2016 21:44: Adrian MM. (X) Created KOG entry
PRO (3): BrigitteHilgner, Adrian MM. (X), AllegroTrans
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Proposed translations
(gen) security interest; (US land) lien; (BrE land) charge
That's why I'm not referring you to the exposition - tucked away in a footnote of English Private Law, Oxford Uni. Press - on the difference between a lien, charge, pledge, mortgage or (Scots) standard security.
All I can add is that, over a probably majestic house in Bozen, a lien would be possible in the US, but not UK - only over an intangible interest ('chose in action') in company shares and in distressed etc. (bankrupt) goods.
A pledge or pawn in both countries (cf. the legendary movie of the Pawnbroker starring Rod Steiger) is generally over tangible goods and, speculatively, bearer-only vs. *mortgageable* registered share certificates ('choses in possession').
http://www.proz.com/kudoz/german_to_english/law_patents/313794-pfandrecht_in_this_context.html
| agree |
AllegroTrans
: Yes, but USA was non-existent in 1237 let us remember (those of us who are old enough)
51 mins
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our native 'First Nation' Amero-Indian spirit guides will.
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Discussion
BTW, standard UK (and Irish, Edith) company & commercial law textbooks used the legalistic term of mortgaging and not pledging co. shares, whereas Anglo-American and German etc. banks, insurance and investment companies will lazily lump together - often in hastily drafted contracts - a pledge of shares, land and investments. Yet 'one size does not fit all'.