No abstract

This article analyses the treatment of non-professional suretyship agreements across the EU in the context provided by Commission initiatives aimed ¢rstly at creating a single market in ¢nan-cial services and secondly at improving the coherence of European private law. Predictably, given their polycontextual function, we are confronted with starkly divergent national approaches towards such agreements: a 'Tower of Babel' rather than a 'common core'. The article proceeds to consider how we may see elements of commonality arising through the tension between the di¡ering national approaches^seen in terms of a Unitary Network. In the course of this analysis the treble paradox of surety protection is described. The article ¢nishes with a prediction of the relevance of a dual-track strategy in this ¢eld: involving measures of sector-speci¢c, vertical harmonisation, and a programme of common-law style, non-legislative harmonisation through judicial convergence.