Liability for foreign negotiable instruments: maker/drawer governed by place of creation, acceptor/indorser by place of payment. The maker or drawer of a foreign promissory note, bill of exchange or cheque is governed in all essential matters by the law of the place where he made the instrument, while the respective liabilities of the acceptor and indorser are governed by the law of the place where the instrument is made payable; this determines consequences such as applicable interest rates when laws differ.
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Liability for foreign negotiable instruments: maker/drawer governed by place of creation, acceptor/indorser by place of payment.
The maker or drawer of a foreign promissory note, bill of exchange or cheque is governed in all essential matters by the law of the place where he made the instrument, while the respective liabilities of the acceptor and indorser are governed by the law of the place where the instrument is made payable; this determines consequences such as applicable interest rates when laws differ.
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