Retention of title in secured transactions law from a creditor's perspective : A comparative analysis of selected (non-)functional approaches

This doctoral research compares the retention of title in Belgium with the retention of title in the United States, Germany and two international instruments (the UNCITRAL legislative guide and model law on secured transactions and Book IX of the Draft Common Frame of Reference. It evaluates the application of the functional approach to retention of title and formulates recommendations concerning the regulation of retention of title in Belgian law.