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EN
The article contains a detailed presentation of the current form of the Spanish land registration system in Spain, taking into account both its organization and substantive rules. In the first part of the article, the Author describes structure and organization of Spanish land register – so called Registro de la Propiedad. Here, the mechanics of recordation shall be discussed, i.e. methods and sufficiency of land description within the Spanish land registration system, methods of recording, indexing and retrieving information, as well as competences, powers and qualifications of recording officers. In this part of the article, the Author describes the historical attempts to digitalize Spanish land register and the current state of their computerization The second part of the paper is devoted to the substantive rules governing land registration in Spain, taking into account the character of titles (titulos) suitable to registration, its declarative effect and the presumptions as well as the public faith principle connected with the registration. Finally, in the last part of the article, the Author tries to indicate the influence of the Spanish Registro de la Propiedad system on land registration methods adopted in selected Latin American countries.
EN
The article contains a detailed presentation of the current form of deeds recordation system in the United States, taking into account both its organization and substantive rules. In the first part of the article, the Author describes structure and organization of American land records. Here, the mechanics of recordation shall be discussed, i.e. methods and sufficiency of land descriptions within the American deeds recordation system, methods of recording, storing, indexing and retrieving information, as well as competences, powers and qualifications of recording officers. The second part of the paper is devoted to the substantive rules governing land recordation in the USA, taking into account the character of documents suitable to recordation, its purely declarative effect and the general lack of public faith of land records. In the third part of the article, the Author tries to characterize American land records as the “private records” i.e. indicate private entities and institutions engaged in the current activity of land records, such as abstractors and title searchers, surveyors and title insurance companies. Finally, in the last part of the article, the Author describes the historical attempts to digitalize Amercican land records and the current state of their computerization.
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