Company law in the UK and securities regulation in the US have developed over the past six decades in response to rapidly changing economic, political and social circumstances. The main features of the regulation of primary securities distributions are identified in the two countries, and their treatment of civil liability is compared.
Robert E. Kohn,
Civil Liability for Primary Securities Distributions in the United States and the United Kingdom,
55 Law and Contemporary Problems
Available at: http://scholarship.law.duke.edu/lcp/vol55/iss4/16