Comparison of legal regulation of a convertible loan agreement in the USA and Russia

This article is devoted to topical aspects of regulation of the convertible loan agreement under the legislation of Russia and the USA. It is noted that in American practice, the convertible loan agreement is widely popular, and therefore its standardized form (the SAFE contractual construction) has been developed and adapted. In Russia, the convertible loan agreement is a novel, the applied significance of which is beyond doubt. However, this agreement has not been reflected in civil legislation. Domestic legal services have attempted to adapt the American experience in the direction of developing a single standard for a convertible loan agreement. It seems that in the near future it is necessary to continue active regulatory and practical work towards improving the mechanism for applying a convertible loan.