proceeds; thus, a filing as to “accounts” automatically would extend to

proceeds.
D. Overlapping Movable Securities Registries
During my 2007 visits to movable security registries in Beijing and
Shanghai, I did not find a unified or networked registry system. A
considerable overlap of what was to be filed the three different registries I
visited. When I inquired about the law that governed the registration of
mortgages and pledges I was referred to the PRC Security Law of 1995.273
A not very reliable English translation of this law by a local firm indicated
that, as also required by the PRL, that mortgages and pledges in real and
tangible personal property required a filing for the security interests to be
valid both inter partes and erga omnes. When I inquired whether this was
the result of importing the German Grunbuch model of registry to China,
one of the registrars who had been a graduate student in Germany said that
this was the case.
Be that as it may. It also appeared from the private English translation
that three different and overlapping registries existed: Supposedly, the main
registry was housed with the “Administration of Industry and Commerce,”
but the directive in the Security

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Law was vague enough to allow “other laws” to dictate registration with
other registries.274 Another registry I visited was the office of a Notary
Public, who explained that his registry was for security rights granted by
private persons “and owners of the real or movable property mortgaged or
pledged.” The third category was of registries of collateral based registries,
such as for automobiles. Nonetheless during my visit it appeared that
registry included all types of “vehicles” such as tractors and mining trucks
(generally considered as equipment by registries in the United States and in
Latin America). I was also told that security rights in the same “vehicles”
were being registered in the Administration of Industry and Commerce as
well as in notarial offices.
Needless to say, that such an unpredictable administrative jurisdiction
only leads to conflicting claims to the perfection and priority of security