| Example: An Italian bank issues a letter of credit that is |
| confirmed by a New York bank. The beneficiary is a Connecticut |
| corporation. The letter of credit provides that the issuer's |
| liability is governed by Italian law, and the confirmation |
| provides that the confirmer's liability is governed by the law of |
| New York. Under Sections 9-306(b) [Maine cite section 9-1306, |
| subsection (2)] and 5-116(a), Italy is the issuer's jurisdiction |
| and New York is the confirmer's (nominated person's) |
| jurisdiction. Because the confirmer's jurisdiction is a State, |
| the law of New York governs perfection and priority of a security |
| interest in the beneficiary's letter-of-credit right against the |
| confirmer. See Section 9-306(a) [Maine cite section 9-1306, |
| subsection (1)]. However, because the issuer's jurisdiction is |
| not a State, the law of that jurisdiction does not govern. See |
| Section 9-306(a) [Maine cite section 9-1306, subsection (1)]. |
| Rather, the choice-of-law rule in Section 9-301(1) [Maine cite |
| section 9-1301, subsection (1)] applies to perfection and |
| priority of a security interest in the beneficiary's letter-of- |
| credit right against the issuer. Under that section, perfection |
| and priority are governed by the law of the jurisdiction in which |
| the debtor (beneficiary) is located. That jurisdiction is |
| Connecticut. See Section 9-307 [Maine cite section 9-1307]. |