L’acquisto graduale della proprietà immobiliare nell’esperienza giuridica statunitense. Gli accordi Lease to own in rapporto al modello nazionale di Rent to buy, in Contr. impresa/Europa

The article analyzes the main models of gradual purchase of real estate in the US system, comparing them with renting to buy contracts in the national panorama. Substantial differences emerge in particular from the comparison between domestic rent to buy contracts and renting to own agreements, both in the negotiation pathology and in the land registration system. The American models reveal numerous critical issues especially with regard to the protection of the most vulnerable subjects; on the other hand, Italian legal experience proves to be more guaranteeing and transparent, but nevertheless these negotiating schemes are struggling to take off due to their management complexity