PROVISION OF BORROWING FACILITIES. 307 



The reason why Germany has relegated chattel credit to a wholly 

 secondary place is (1) that as the landlord has by law the first rights 

 over the crops and stock of the farm up to the amount of his rents, it 

 is impossible to pledge them by delivery to a third party without 

 wronging the landlord, unless with his consent ; (2) that crops and 

 stocks and furniture by their very nature cannot be removed or deli- 

 vered to the custody of the pledgee without disturbing or preventing 

 the work of the farm. In Germany, therefore, while personal credit 

 largely depends upon a consideration of the possessions of the borrower, 

 those possessions are not themselves given actually, in pledge, and 

 chattel credit is practically of little use. This is equally the case in 

 France, but the course of action has been vastly different ; the business 

 men of Germany, abandoning the idea of chattel credit, have sought de- 

 velopment of personal credit, while their confreres in France have either 

 unceasingly discussed the possibilities of developing chattel credit, so 

 that the debates on the Credit Agricole in France have been largely 

 synonymous with debates on the restriction of the landlords' privileges 

 as entered in the Civil Code, the pledge without delivery, the assimila- 

 tion of the present borrower to the commercant, and his subjection to 

 the commercial law and Courts, or they have attempted to provide 

 agricultural credit, which deals with petty transactions over the face 

 of a whole country, by means of central institutions which could not 

 possibly touch the difficulties. Hence the actual result is, that in 

 France, where it is extremely difficult to alter the law, altogether apart 

 from the practical difficulties in the way of chattel credit, the Credit 

 Agricole is, still, a matter of discussion, and the peasant is actually 

 without agricultural credit, except in so far as the rs.ial money-lender 

 will grant it ; whereas in Germany certain practical minds borrowing 

 the principles of association, unlimited liability and local effort from 

 the Landschaften of their own country and the Banks of Scotland, 

 have founded the popular banks and credit institutions, which, though 

 not yet f vlly developed, have, so far as they have gone, solved the 

 problem of credit to the petty proprietor, artisan or tradesman, and 

 while so d^ing have fostered and are fostering precisely those habits 

 of thrift, temperance, prudence, punctuality, public spirit, enterprise 

 and combination, which are the substructure of all permanent and 

 substantial progress. France has discussed legal improvements and 

 ' central institutions, the idea of the latter being based on the success 

 of the Credit Foncier, and being equally consonant with the 



