lien, which was implemented by Article 9 of the Uniform Commercial Code and is a lien that expanded to cover any additional property that is acquired by the lienee while the debt is outstanding. A critical difference between the floating charge and the floating lien is that UCC security interests, including floating liens, can be granted by any kind of debtor, including individuals or partnerships (and will thus have priority in bankruptcy), whereas the floating charge can be granted only by corporate entities. The U.S. never adopted the floating charge directly because at the time it was developing in England in the 19th century, U.S. courts generally held that a debtor simply could not create a security interest in future property; general creditors ought to have a pool of unencumbered assets to look to; and even if such a thing could exist, it was a fraudulent conveyance. However, creditors' lawyers gradually developed an diverse variety of methods, some authorized by state legislatures and others tolerated by state courts, to evade the general ban on security interests in future property. As it had become clear that creditors and debtors were going to find ways to create enforceable de facto security interests in after-acquired property and general intangibles whether courts liked it or not, the UCC drafters in the 1940s (particularly Grant Gilmore) successfully argued that such interests should be legitimized and simplified in the form of the floating lien. Quebec When the Quebec Civil Code came into force in 1994 and superseded the Civil Code of Lower Canada, it abolished the charge flottante "floating charge" and created and introduced an analogous security device into Quebec law under the name hypothèque ouverte, or "floating mortgage". As a mortgage, it can be taken over immovables and movables (real and personal property); must be in due form, i.e. passed before a notary and registered; confers rights in rem including priority ranking, right of pursuit (that is, it runs with the land and cannot be defeated by a bona fide purchaser), creditor's consent required to dispose of subject; and grants powers of recourse, including repossession, judicial foreclosure, sale by mortgagee in possession, or administrative receivership. The floating mortgage can be specific or general with respect to immovables and movables, separately or together. The mortgage is not perfected until it crystallises. Crystallisation occurs upon default of the mortgagor and registration of a notice of default, and