My objective in this paper is to compare and to evaluate some of the features of the American and Chinese systems. I do so without any preconception that the American system provides better answers, but with the recognition that it is far more mature and provides more answers. Hence it provides a reference point from which the Chinese system can be considered. Perhaps each system has something to teach the other.
Dale A. Whitman, Chinese Mortgage Law: An American Perspective, 15 Colum. J. Asian L. 35 (2001)