Revised Article 9 states that the proper place to file a financing statement for a foreign debtor is in the District of Columbia, UNLESS the foreign jurisdiction in which that debtor is located maintains a system to perfect security interests by filing or recordation.
But which foreign countries are considered to have filing systems equivalent to the United States, and which are merely exotic tourist destinations?
The UCC Committee of the California Bar Association tackled this thorny issue by studying the filing regimes of 74 countries from Albania to Vietnam. Their results were published in the UCC Law Journal in 2006. 39 U.C.C. L.J. 109 (Nov. 2006).
Hopefully this study will provide guidance to lawyers and secured lenders. Capitol Services cannot provide legal advice or assistance in determining where to file.
Click https://www.capitolservices.com/images/ForeignUCCDebtors.pdf to view the document.