一、介绍现代资产证券化交易是在20世纪70年代初期由美国政府机构创设的。此后这种交易又被一些私人公司所采纳。随着资产证券化交易规模的扩大,统计显示私人公司从交易中获得了大量的利润,其他国家的公司和立法者开始探索如何在本国开展资产证券化。其中包括了两个最发达的大陆法系国家:法国和德国。 I. Introduction Modern securitization transactions were created by U.S. government agencies in the early 1970s. Since then the deal has been adopted by some private companies. With the expansion of asset securitization, statistics show that private companies have made substantial profits from the transaction, and companies and legislators in other countries have started to explore how to conduct asset securitization in their own countries. Including two of the most developed countries of continental law: France and Germany.