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Property-Liability Underwriting under the Continental Civil Codes
Darwin B. Close
The Journal of Risk and Insurance
Vol. 37, No. 4 (Dec., 1970), pp. 621-626
Published by: American Risk and Insurance Association
Stable URL: http://www.jstor.org/stable/251071
Page Count: 6
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This paper discusses aspects of the systems of coded law currently existing in Western Europe which are important to underwriting property and liability risks. Contrasts with concepts of contributory and comparative negligence as they are generally understood in the United States are drawn so that an American underwriter might be able to function profitably in the Western European market. Specific situations of strict liability are described as they exist in several of the countries and those differences between the several codes of law which of importance to liability underwriting are described. This article is designed to alert American insurance interests to the general differences which exist in order to minimize the effects of misconceptions which might result in adverse loss results should this market be entered.
The Journal of Risk and Insurance © 1970 American Risk and Insurance Association