¹ Orazio Mastroeni, Pfandbrief-style products in Europe, European Central Bank, BIS Papers No.5, 63.Google Scholar

² Other terms have been use in its description, including, credit squeeze, credit bubble, housing crisis, and distressed credit market crisis.Google Scholar

³ José Manuel González-Páramo, Financial turmoil, securitisation and liquidity, 3, Global ABS Conference 2008, Cannes, 1 June 2008.Google Scholar

⁴ See Gesetz zur Neuordnung des Pfandbriefrechts, 22 May, 2005; amendments beyond this date will not be considered.Google Scholar

⁵ See Norton Rose LLP, German Pfandbriefe: a modern financing tool in demand, client publication (December 2008) available at http://www.nortonrose.com/knowledge/publications/2008/pub18574.aspx?page=all&lang=en-gb, (last visited Feb. 5, 2009).Google Scholar

⁶ See Verband Deutscher Pfandbriefbanken (‘VDB'), Representing Germany's Pfandbrief Banks, available at http://www.pfandbrief.de/d/internet.nsf/tindex/en_about.htm, (last visited Feb. 5, 2009). This is the lobbying body for the group of approximately 36 banks that are engaged in the Pfandbrief market.Google Scholar

⁷ See Pfandbriefbanken, Verband Deutscher, The Pfandbrief – a premium product, 16, presentation prepared for analysts’ conference call (26 Feb. 2008) available at http://www.pfandbrief.de/d/internet.nsf/0/346DAA456C29D09AC125741F00254245/$FILE/PfandbriefPremiumProduct.pdf (last visited Feb. 5, 2009).Google Scholar

⁸ Id. 4.Google Scholar

⁹ Hypothek is one way of presenting the idea of a real property mortgage. The word Grundshuld is also sometimes used and may be translated as “Abstract land charge”.Google Scholar

¹⁰ Even if it did, there are many other aspects to land transfer that would not find equivalent meaning. For example, the time periods and other procedures involved in standard land transfer or in registration or discharge of a mortgage.Google Scholar

¹¹ F.H Lawson, The Field of Comparative Law, 61 Jurid. Rev 16 (1949).Google Scholar

¹² See Dodd, Randall, Subprime: Tentacles of a Crisis, 44 Fin. & Dev. 15 (International Monetary Fund Dec. 2007) (stating that the early roots of a secondary market for housing mortgages arguably lie in Roosevelt's New Deal, and the founding in 1938 of the Federal National Mortgage Association (Fannie Mae)).Google Scholar

¹³ See Shy, Oz & Stenbacka, Rune, Rethinking the Roles of Banks: A Call for Narrow Banking, The Economists’ Voice: Vol. 5: 2 (2008) available at http://www.bepress.com/ev/vol5/iss2/art6 (stating that notwithstanding the UK's Northern Rock and other bailouts, some have used this disaster as a basis to argue for drastically “narrower” (simplified, less risky, more transparent) banking services for those who want them). The average Northern Rock depositor and the UK government would perhaps both have been glad of this advice.Google Scholar

¹⁴ See supra José Manuel González-Páramo, note 2.Google Scholar

¹⁵ See ESF Securitisation 2008 Market Outlook, European Securitisation Forum, available at www.europeansecuritisation.com.Google Scholar

¹⁶ The Bank of England supplied emergency financial aid to this mortgage lender on 14 September, 2007; it was subsequently nationalized on 22 February 2008. This fiasco included the first bank run in Britain in roughly 140 years.Google Scholar

¹⁷ See Gumbel, Peter, Subprime on the Rhine, Fortune, 3 Sept. 2007, available at http://w4.stern.nyu.edu/news/news.cfm?doc_id=7571 (listing IKB Deutsche Industriebank as a Düsseldorf-based commercial bank).Google Scholar

¹⁸ Recently purchased 1 January 2008 by the Stuttgart-based Landesbank Baden-Wurttemberg.Google Scholar

¹⁹ See Dempsey, Judy, Iceland's Government Collapses, New York Times, 26 Jan. 2009.Google Scholar

²⁰ See Standard & Poors, German Banks’ Subprime Mortgage And Structured Vehicle Exposure Concerns Are Overstated (19 Sept. 2007) (“… we consider that credit risk in the German banking sector from U.S. subprime mortgage exposures is limited as it is generally concentrated in the ‘AAA’ and ‘AA’ rated tranches and we consider the potential market valuation effects to be manageable.”).Google Scholar

²¹ See Verband Deutscher Pfandbriefbanken (Association of German Pfandbrief Banks), Analysts’ Conference Call, 20, 26 Feb. 2008 (noting that there was limited exposure to apartments and multi-family dwellings but no exposure to single-family housing). This is for to say that some German banks did not buy US sub-prime assets and suffer the consequences. IKB Deutsche Industriebank is one example. See Subprime on the Rhine, Fortune, 9 March 2007.Google Scholar

²² See BaFin web page, www.bafin.de. “BaFin has 1,600 employees working in Bonn and Frankfurt am Main. They supervise around 2,079 banks, 718 financial services institutions, 633 insurance undertakings, 26 pension funds, 6,000 investment funds and 78 investment companies (as of January 2008). BaFin operates only in the public interest. Its primary objective is to guarantee the proper functioning, stability and integrity of the German financial system. Bank customers, insurance policyholders and investors are meant to be able to trust the financial system. Under its solvency supervision remit, BaFin ensures the ability of banks, financial services institutions and insurance undertakings to meet their payment obligations. Through its market supervision, BaFin also enforces standards of professional conduct which preserve investors’ trust in the financial markets. BaFin also has an investor protection role in that it seeks to prevent unauthorised financial business being carried out.”Google Scholar

²³ Most notably the ability to render a “true sale” of debts that have been securitized under Article 9 of the Uniform Commercial Code.Google Scholar

²⁴ Christopher Lewis Peterson, Over-Indebtedness, Predatory Lending, and the International Political Economy of Residential Home Mortgage Securitization: Comparing the United States’ Subprime Home Mortgage Lending Crisis to Home Finance in the United Kingdom, Germany, and Japan, SSRN Paper (11 Jan. 2008) available at http://ssrn.com/abstract=1083184.Google Scholar

²⁵ Michael Kern & Werner Meier (Cleary Gottlieb Steen & Hamilton LLP), Chapter 20 - German in The International Comparative Legal Guide to: Securitisation 2007, (Global Legal Group, 2007).Google Scholar

²⁶ See Merriman, John, A History of Modern Europe from the Rennaisance to the Present, 432–434 (WW Norton & Co. 1996). Frederick II of Prussia, also known as “Frederick the Great”, his rule was known for its “enlightened absolutism,” judicial reforms, an examination system for entry into the state bureaucracy, bolstering the position of Prussian nobles (e.g. he maintained serfdom in the private estates while others were working for its abolition), prohibiting marriage between nobles and commoners, and preventing the sale of noble lands to commoners‥Google Scholar

²⁷ Frederiksen, D. M., Mortgage Banking in Germany, 9 Q. J. of Econ. 47, (1894) [hereafter Frederiksen].Google Scholar

²⁸ See Giles MacDonogh, Frederick the Great: A life in Deed and Letters (2001).Google Scholar

²⁹ Id. at 47 (translation as published in Der Deutsche Oekonomist, 3 June 1894).Google Scholar

³⁰ Frederiksen, supra note 27, at 51.Google Scholar

³¹ Kur and Neumark, 1777; Pommern, 1780; Hamburg, 1782; Westpreussen, 1787; Ostpreussen, 1788; Lüneburg, 1791; Schleswig-Holstein, 1811; Mecklenburg, 1818 and 1840; Posen, 1822; Würtemberg, 1825; Calenberg, Grubhagen, and Hildesheim, 1825; Bremen an Verden, 1826. Frederiksen, p. 52.Google Scholar

³² Frederiksen, supra note 27, at 48.Google Scholar

³³ Also called a Hypothekencasse.Google Scholar

** 34 Which might also be named “provincial mortgage coupons” or in more modern parlance, debentures.Google Scholar

³⁵ Frederiksen, supra note 27, at 48.Google Scholar

³⁶ Id. at 48.Google Scholar

³⁷ As opposed to any form of receivership “for on that rests an eternal curse.” Frederiksen, supra note 27, at 48.Google Scholar

³⁸ See id. at 49.Google Scholar

³⁹ Land owners would apparently “borrow” cattle from neighbors of the purposes of valuation. See id. at 48.Google Scholar

⁴⁰ See id. at 48.Google Scholar

⁴¹ Id. at 60.Google Scholar

⁴² Id. at 55.Google Scholar

⁴³ See id. at 55.Google Scholar

⁴⁴ See id. at 56. The amount of the loan was not to exceed the actual cost of the building.Google Scholar

⁴⁵ Id. at 56.Google Scholar

⁴⁶ Id. “Usually, the amount that may be loaned by the credit associations is limited, so as to be within a certain proportion of the assessed valuation of the property.” Id.Google Scholar

⁴⁷ Graham “Harry” Cross, The German Pfandbrief and European Covered Bonds Market in The Handbook of European Fixed Income Securities, [hereinafter Cross] 201, note 1 (Frank J. Fabozzi & Moorad Choudhry eds., 2004).Google Scholar

⁴⁸ In Anglo-American systems a pledge is a very old form of security. As far back as 1703, Chief Justice Holt noted that the “fourth sort [of bailment] is, when goods or chattels are delivered to another as a pawn to be a security to him for money borrowed of him by the bailer; and this is call in Latin vadium, and in English a pawn or a pledge.” Coggs v. Barnard, 92 Eng. Rep. 999 (2 Ld. Raym, 909) (1703).Google Scholar

⁴⁹ They are also sometimes translated as “bank debentures”. The distinction between “bond” and “debenture” is not strictly upheld in modern finance.Google Scholar

⁵⁰ Cross, supra note 47, at 201–202.Google Scholar

⁵¹ See id. at 202.Google Scholar

⁵² Questions on German Covered Bond Legislation, Dr Otmar Stöcker, Managing Director, Association of German Pfandbrief Banks, 13.9.06 on file with author; See also §2(1) of Pfandbrief Act.Google Scholar

⁵³ See Act, Pfandbrief, §2(2).Google Scholar

⁵⁴ See id. §2(3).Google Scholar

⁵⁵ See id. §3.Google Scholar

⁵⁶ Id. §3Google Scholar

⁵⁷ Id. §4(1).Google Scholar

⁵⁸ Net Present Value is the “discounted value of an investment's cash inflows minus the discounted value of its cash outflows. To be adequately profitable, an investment should have a net present value greater than zero. Net present value is a tool for evaluating an investment proposal.” The American Heritage Dictionary of Business Terms, Houghton Mifflin Harcourt (2009). According to §4(6) of the Covered Bond legislation, the Federal Ministry of Finance (Bundesministerium der Finanzen) together with the Federal Ministry of Justice (Bundesministerium der Justiz) may promulgate rules for calculating the net present value.Google Scholar

⁵⁹ See Act, Pfandbrief, §4 (2) 1, 2, & 3 (providing a full list).Google Scholar

⁶⁰ See id. §4(4).Google Scholar

⁶¹ Id. §4(5).Google Scholar

⁶² Id. §4(7). This provision goes on to prohibit sale to the detriment of “the creditors of claims under derivatives pursuant to para. 3 despite the remaining assets recorded in the respective register not being sufficient to cover as prescribed the respective Pfandbriefe and the claims under derivatives pursuant to para. 3.”Google Scholar

⁶³ See id., §4(7).Google Scholar

⁶⁴ See id. §1(1) sentence 2, numbers 1–3.Google Scholar

⁶⁵ European Economic Area. Members are signatories of the Agreement on the European Economic Area (EEA) (1991) also knows as the “Porto Treaty”. The Treaty permits countries to be part of certain economic aspects of the EU (the “four freedoms”) without being obliged under political aspects.Google Scholar

⁶⁶ See Act, Pfandbrief, §41(2).Google Scholar

⁶⁷ Id. §5(1).Google Scholar

⁶⁸ See id. §6(1).Google Scholar

⁶⁹ Id. §6(2) and §6(3).Google Scholar

⁷⁰ Id. §7(1).Google Scholar

⁷¹ Id. §7(2) (prohibiting partiality). Those with employment or client relationships with the bank during the previous three years are excluded on this ground.Google Scholar

⁷² See id. §7(2).Google Scholar

⁷³ See id. §7(3).Google Scholar

⁷⁴ See id. §7(4).Google Scholar

⁷⁵ See id. §8(1), last sentence.Google Scholar

⁷⁶ See id. §8(3).Google Scholar

⁷⁷ See id. §8(4).Google Scholar

⁷⁸ See id.Google Scholar

⁷⁹ See id. §9(1) and (2).Google Scholar

⁸⁰ See id. §9(3).Google Scholar

⁸¹ See id. §10(1).Google Scholar

⁸² See id. §10(2).Google Scholar

⁸³ See id. §11(1).Google Scholar

⁸⁴ See id. §11(2).Google Scholar

⁸⁵ See id. §27(1).Google Scholar

⁸⁶ Id. §27(1) (Allen and Overy translation, 60).Google Scholar

⁸⁷ See Pfandbrief Act §27(2).Google Scholar

⁸⁸ Compared to those required for certain products in other countries, especially the USA. See generally Bobby R. Bean, Enhancing Transparency in the Structured Finance Market, 5 Supervisory Insights 4 (2008).Google Scholar

⁸⁹ See Pfandbrief Act §27(1)(2).Google Scholar

⁹⁰ See id. §28(3) & §28(4).Google Scholar

⁹¹ See id. §28(5).Google Scholar

⁹² Chapter 6, Pfandbrief Act, Legal Remedies and Offences.Google Scholar

⁹³ See id. §38(1). The central cover provision is §4(7) sentence 1.Google Scholar

⁹⁴ See id. §39 (1) & §39(2).Google Scholar

⁹⁵ Hypothekenpfandbriefe.Google Scholar

⁹⁶ See Annex A1 to Boos, Görke, & Hoegen, infra note, at 120 (Defining the Public Pfandbrief to include “the issue of covered bonds on the basis of acquired claims against public sector bodies designated as public sector bonds (Kommunalschuldverschreibungen), public sector debentures (Kommunalobligationen) or public Pfandbriefe (Öffentiche Pfandbriefe)).Google Scholar

⁹⁷ The Act does not cover Aircraft Pfandbriefe.Google Scholar

⁹⁸ Annex A1 to Boos, Görke, & Hoegen, infra note 120, at 48.Google Scholar

⁹⁹ Gesetz zur Neuordnung des Pfandbriefrechts Vom 22 Mai 2005, Bundesgesetzblatt Jarhgang 2005 Teil I, Nr. 29 (promulgated at Bonn on 27 May 2005).Google Scholar

¹⁰⁰ The right must also not exceed “the time period required for the book depreciation of the building in line with economic principles” (Bundesverband Öffentlicher Banken Deutschlands translation. P. 54.)Google Scholar

¹⁰¹ Pfandbrief Act 16(2).Google Scholar

¹⁰² Id.Google Scholar

¹⁰³ Id.Google Scholar

¹⁰⁴ Id.(Bundesverband Öffentlicher Banken Deutschlands translation, 54).Google Scholar

¹⁰⁵ See BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) (providing the issues inherent in calculating the market value based on the price at a forced sale). According to the US Supreme Court “The market value of a piece of property is the price which it might be expected to bring if offered for sale in a fair market; not the price which might be obtained on a sale at public auction or a sale forced by the necessities of the owner, but such a price as would be fixed by negotiation and mutual agreement, after ample time to find a purchaser, as between a vendor who is willing, but not compelled, to sell and a purchaser who desires to buy but is not compelled to take the particular piece of property. In short, “fair market value” presumes market conditions that, by definition, simply do not obtain in the context of a forced sale.” Id.Google Scholar

¹⁰⁶ See R. v Islam, [2009] UKHL 30 [2009] (According to the House of Lords “A market, after all, is a place where goods are bought and sold. The market value of goods is the price that they will fetch in that market. It is the price which a willing seller will accept for them from a willing buyer.”), available at http://www.bailii.org/uk/cases/UKHL/2009/30.html.Google Scholar

¹⁰⁷ Annex A1 to Boos, Görke, Hoegen, infra note 120, at PfandBG §17(1).Google Scholar

¹⁰⁸ See Annex A1 to Boos, Görke, Hoegen, infra note 120, at 55, (stating that under §17(2) this will be permitted if “this appears justified due to other liabilities of the debtor related to the granting of the loan, taking into account the condition and the permanent features of the mortgaged property.”).Google Scholar

¹⁰⁹ Again, with compliance with certain EU Directives.Google Scholar

¹¹⁰ These conditions are: “1. a right in rem (dingliches Recht) can be created in respect of ships and ships under construction, which is recorded in a public register; 2. the right in rem grants the creditor security which is similar to a ship mortgage under German law and, in particular, the right to seek satisfaction under the secured loan claim from the ship or the ship under construction; 3. it is not significantly more difficult to bring an action for creditors of other nationalities as compared to their fellow nationals.” Boos, Görke, Hoegen, infra note 120, at 58.Google Scholar

¹¹¹ See Pfandbrief Act §22(2).Google Scholar

¹¹² See id. §22(4).Google Scholar

¹¹³ See id. §24(1).Google Scholar

¹¹⁴ Id. §24(2).Google Scholar

¹¹⁵ See id. §24(2).Google Scholar

¹¹⁶ Id. §24(2).Google Scholar

¹¹⁷ Annex A1 to Boos, Görke & Hoegen, infra note 120, at 53.Google Scholar

¹¹⁸ Pfandbrief Act§20; see Annex A1 to Boos, Görke & Hoegen, infra note 120, at 56. Other entities also capable of supporting Public Pfandbriefe include full members of the OECD, certain banks.Google Scholar

¹¹⁹ Annex A1 to Boos, Görke & Hoegen, infra note 120, at 56Google Scholar

¹²⁰ Karl-Heinz Boos, Oliver Görke & Peter Hoegen, Das neue Pfandbriefgesetz-Starkung des Finanzplatzes Deutchland [The New German Pfandbrief Act: Strengthening Germany as a Financial Centre], Allen & Overy, at 62 (May 2005).Google Scholar

¹²¹ See Questions on German Covered Bond Legislation Dr Otmar Stöcker, Managing Director, Association of German Pfandbrief Banks, 13 Sept. 2006.Google Scholar

¹²² Id.Google Scholar

¹²³ Pfandbrief Act §30 (2), sentence 2. If the Pfandbrief bank has disposed of an asset recorded in the cover register after the appointment of the cover pool administrator, such disposal shall be invalid (sentence 3).Google Scholar

¹²⁴ See id. §32 (I).Google Scholar

¹²⁵ See id. §30(2).Google Scholar

¹²⁶ Id. §30(3).Google Scholar

¹²⁷ Id. §30(3).Google Scholar

¹²⁸ Id. §30(4).Google Scholar

¹²⁹ See id. §30(4), sentence 2.Google Scholar

¹³⁰ See Principally §46a of the Banking Act (Kreditwesengesetzes); Pfandbrief Act §30(5), sentence 1.Google Scholar

¹³¹ See Pfandbrief Act §30(8).Google Scholar

¹³² See id. §31(1), sentence 4.Google Scholar

¹³³ See id. §31(1), sentence 1 (giving authority to the court “having jurisdiction at the seat of the Pfandbrief bank.”). The “seat” refers to the place of management under German Sitztheorie (“seat theory”). This may be compared to the place of incorporation theory (Gründungstheorie) more commonly found in common law systems.Google Scholar

¹³⁴ See id. §31(1) sentence 3This must occur at the request of the Federal Authority;.Google Scholar

¹³⁵ See id. §31(2), sentence 3. In cases under §33(5) the Genossenregister (register of co-operatives) is appropriate.Google Scholar

¹³⁶ See Pfandbrief Act §31(3) sentence 1. This will depend on the circumstances the nature of the right.Google Scholar

¹³⁷ See id. §31(3) sentence 4.Google Scholar

¹³⁸ See id. §31(4).Google Scholar

¹³⁹ See id. §31(5). Annual financial statements and an annual administration report are also required. The financial statement must be audited (§31(5) sentence 2.Google Scholar

¹⁴⁰ See id. §31(6) sentence 1.Google Scholar

¹⁴¹ See id. §31(6).Google Scholar

¹⁴² See id. §31(1).Google Scholar

¹⁴³ Id. §31(4).Google Scholar

¹⁴⁴ Pfandbrief Act §35(1) sentence 1 (Allen & Overy translation, 66).Google Scholar

¹⁴⁵ See Pfandbrief Act §35(2).Google Scholar

¹⁴⁶ See id. §35(3).Google Scholar

¹⁴⁷ Gesetz zur Neuordnung des Pfandbriefrechts “PfandBG” [Pfandbrief Act], Bundesgesetzblatt [Federal Law Gazette], Part I, 1373, 27 May 2005.Google Scholar

¹⁴⁸ Specifically, the Act on Pfandbriefe and Related Bonds of Public Sector Credit Institutions (Gesetz über die Pfandbriefe und verwandten Schuldverschreibungen öffentlicher-rechtlicher Kreditanstalten; ÖPG); the Mortgage Bank Act (Hypothekenbankgesetz; HBG); the Act on Ship Pfandbrief Banks (Gesetz über Schiffspfandbriefbanken; SchBkG).Google Scholar

¹⁴⁹ See Pfandbrief Act §2 (§2 PfandBG).Google Scholar

¹⁵⁰ See Pfandbrief Act §27 (providing for Risk Management).Google Scholar

¹⁵¹ Karl-Heinz Boos, Oliver Görke & Peter Hoegen, Das neue Pfandbriefgesetz-Starkung des Finanzplatzes Deutchland [The New German Pfandbrief Act: Strengthening Germany as a Financial Centre], 10 Allen & Overy (May 2005).Google Scholar

¹⁵² See Renzo G. Avesani, Antonio García Pascual & Elina Ribakova, Appendix II: Regulatory Framework for Pfandbriefe and Cédulas Hipotecarias Mortgage Pfandbriefe: A New Regulatory Framework in The Use of Mortgage Covered Bonds, 20, IMF Working Paper, WP/07/20, (2007). This Working Paper does not represent the views of the IMF.Google Scholar

¹⁵³ See Kettering, Kenneth C., Securitization and Its Discontents: The Dynamics of Financial Product Development, 29 Cardozo L. Rev. 1553; NYLS Legal Studies Research Paper No. 07/08-7 (2008) (explaining the criticism by leading authors criticizing of this magic), available at SSRN: http://ssrn.com/abstract=1012937 Google Scholar

¹⁵⁴ Greg Ip, FDIC Might Set a Policy View on New Mortgage Funding, The Wall Street Journal, A12, 7 March 2008.Google Scholar

¹⁵⁵ Bert Ely, Let's Try Market-Oriented Reform, The Wall Street Journal, A11, 31 May 2008.Google Scholar

¹⁵⁶ See Solomon, Deborah, U.S. Pushes a European Method To Help Banks Make Home Loans ‘Covered Bonds’ May Lure Investors Wary of Defaults, Wall Street Journal, A3, 17 June 2008. Solomon notes that “Some analysts have predicted that a covered-bond market in the U.S. could grow to $1 trillion over the next few years. Currently, the market is minuscule compared with the $11 trillion in home mortgages outstanding in the U.S. …Covered bonds are considered safer investments because they stay on a bank's balance sheet and the buyer of the bonds gets double protection. The bonds are backed first by a “cover pool” of high-quality mortgages that must meet certain criteria, such as being in good standing. If the mortgages go bad, the bank must step in to ensure bond holders get their interest.” Id.Google Scholar

¹⁵⁷ Id.Google Scholar

¹⁵⁸ See id.Google Scholar

¹⁵⁹ See id.Google Scholar

¹⁶⁰ See id.Google Scholar

¹⁶¹ Press Release, Federal Deposit Insurance Corporation, Federal Deposit Insurance Corporation on Covered Bond Policy Statement (15 July 2008), available at http://www.fdic.gov/news/news/press/2008/pr08060a.html (last visited Feb. 3, 2009).Google Scholar

¹⁶² Heidi N. Moore, Deal Journal – Path to Cash: Covered Bonds - FDIC Urges Banks to Issue Securities; Huge Market in Europe, The Wall Street Journal, 17 July 2008, C3.Google Scholar

¹⁶³ HM Treasury Press Release, 120/07, 8 November 2007, Government to implement covered bonds regime in March 2008. For the relevant Directive see 85/611/EEC.Google Scholar

¹⁶⁴ David Uren, Mortgage bundling supported, The Australian, 24 June 2008, p.23, discussing the approach of the Australian Prudential Regulation Authority (APRA).Google Scholar

¹⁶⁵ Renzo G. Avesani, Antonio García Pascual & Elina Ribakova, Appendix II: Regulatory Framework for Pfandbriefe and Cédulas Hipotecarias Mortgage Pfandbriefe: A New Regulatory Framework in The Use of Mortgage Covered Bonds, 20, IMF Working Paper, WP/07/20 (2007). This Working Paper does not represent the views of the IMF.Google Scholar