ABSTRACT
The Convention on International Interests in Mobile Equipment and an associated Protocol on Matters Specific to Aircraft Equipment was adopted at a diplomatic conference in November of 2001. The basic structures of the Convention and Aircraft Protocol were developed by the International Institute on Unification of Private Law. Secured financing law is grounded in concepts of property, some of which are peculiar to particular families of law. The North American systems represent a genuine attempt to have secured financing law that reflects the needs of the persons directly affected by it, and that, as much as possible, is free from traditional, outmoded legal concepts. A very similar issue arises in the context of conditional sales agreements. Article 5(3) of the Convention provides that references to the applicable law are to the domestic rules of law applicable by virtue of the rules of private international law of the forum State.
