The system of alienation guarantee is an untypical guarantee system that developed gradually through absorbing Fiducia Theory in Roman Law by civil law countries ( Germany Japan, our Taiwan areas, etc.) and needs transfer the rights of the subject. 让与担保制度是由大陆法系德日等国沿袭罗马法上的信托行为理论而逐渐发展起来的,须转移标的物上权利的非典型担保制度。
Mortgage, as a kind of security, which was originated from the ancient security system of Fiducia in Roman law, had acquired development and maturity in Common Law. 按揭这一担保形式,源于罗马法的古老的信托质担保方式,发展并成熟于英美法系国家。