Il collegamento negoziale nel credito al consumo alla luce della direttiva 2008/48/CE

This thesis is about the topic of liability of creditor for breaches by supplier in onsumer credit operations. The first chapter analyses the framework of law, on this subject, in Germany, France and United Kingdom before the entrance into force of the directive 87/102/CE. The second chapter concerns the questions raised up by the first European directive on this subject, in the light of its transposition in our national legal system and its practical applications by the Courts. The third chapter, throw a reasoned and a critical analysis of the innovations arising from the new directive 2008/48/CE, puts forward the most important problems of interpretation related to the national law of transposition. The last chapter shows the unsuitability of the shape of directives of maximum harmonization. In this context, the Author proposes, in the light of general principles of contract law, a new interpretation of the provisions about this topic and an improved protection of the consumer