located. Where a diversified portfolio of securities with issuers from a number of jurisdictions is involved, the laws of a number of different jurisdictions may be applicable. Uncertainties as to the approach, and of the look-through approach, if applicable, lead to significant expense for market participants. Because the position in many cases cannot be satisfactorily determined, there remains an element of systemic risk. Personal or contractual claim If an investor holds merely contractual rights against its intermediary for delivery of securities, it no longer seems accurate to refer to the lex rei sitae, which is a property law concept. Rather, the applicable law has to be ascertained by reference to the conflict of laws principles for contractual matters. These principles would lead to the application of the law of the intermediary, be it under the heading of the "characteristic obligation", "the most significant relationship" or "the proper law". Alternatives The "Place of the Relevant Intermediary Approach" (or "PRIMA") is increasingly being favoured over the look-through approach. It is the basis for the Hague Securities Convention, which if ratified, will supersede the look-through approach globally. In January 2001, at the first Special Commission of the Hague Securities Convention, the look-through approach was resoundingly rejected by the 119 experts in attendance. Securities (finance)