IN SEARCH OF THE STRUCTURE OF EUROHYPOTHEC ( W poszukiwaniu konstrukcji eurohipoteki)
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The existence of different mortgage law systems in each of the EU Member States makes cross-border lending difficult and impedes the free development of common capital market in the European Union. One of the solutions to the problem could be a common mortgage for Europe (Eurohypothec). The article presents the results of academic research up to date and analyses models for a Eurohypothec proposed by several research groups. At the same time, the author presents the development and economic importance of a European mortgage market and outlines the history of Eurohypothec. In this context, the documents of the EU Institutions and positions of the Member States regarding the project are discussed. The main focus of the research is the legal structure of the Eurohypothec. Taking into consideration different opinions, the article seeks to establish the best model while examining closely the problems of accessory and independent mortgage. Although the author expresses some reservations, he generally promotes the idea of the Eurohypothec.
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