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The American Securities Act and Its Foreign Counterparts: A Comparative Study

Kessler, Friedrich
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Faculty Scholarship Series
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Abstract
The likeness of parts of the Securities Act to the corresponding provisions of the British Companies Act of 1928-9 has caused many reviewers of the Securities Act to compare it, either incidentally or fully, with the cognate provisions of the English Act. A more comprehensive comparative study, including the most important Continental legal systems, has not yet been written. This article attempts that study.
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http://hdl.handle.net/20.500.13051/2054