the ones mentioned. This means that rather than focusing on a single best choice to locate the registry, the options should be open to existing institutions with the required capacity. While such systems are typically fully automated, human capacity for purposes of operating modern IT systems is required. It is important that whichever institution is mandated or chosen to operate the collateral registry has the infrastructure and financial capacity to operate the registry. Some jurisdictions choose to outsource the technical operations of the registry to a service provider, even though the data continues to be public data (unlike the data gathered by private credit bureaus). Many governments simply will not contemplate turning over operation of a registry to a private party.<sup>24</sup> Some are more amenable to this idea.<sup>25</sup> Each case will determine what the best options are in terms of institutional set up. The key aspect will be to create a registry which contains the main operating principles of a modern registry, and not which institution is in charge of managing it.

Finally, the other important aspect that needs to be analyzed with regard to the registration of security interests in movable property is the level of development of technology infrastructure in a country. There are two perspectives from which to assess a country’s technology infrastructure and capacity to support an Internet-based registry. The first is the perspective of the registry, and the second is the perspective of the end user. _From the registry’s perspective_ , which is concerned with the ability of the infrastructure to meet the needs of an electronic registry, the important components are (i) connectivity with the Internet, (ii) presence of facilities to support registry hardware, and (iii) availability of people with the right skill sets to support the technology components. _From the end user’s perspective_ , the key question is whether all potential users of the registry’s services have access to the Internet in some fashion. The potential users whose needs must be considered include banks, inventory financers such as manufacturers and wholesalers, buyers of farm products, lessor, non-bank financial institutions (NBFI) and the public at large. If users do not have access across the country, it will be necessary to provide intake points (through private providers with internet access or public offices) in outlying regions to which users who do not have access may take paper documents, either for entry as data via the Internet from the intake points or for transmission to the central registry location via fax or some other means.

In the MENA region, the concepts behind security interests notice filing are not well understood. As of yet, there are no registries in MENA that function as modern notice filing collateral registries. MENA is the only region worldwide which has not yet managed to create a modern collateral registry system. Several of the countries in the MENA region have registries as

> 24 _Secured Transactions Systems and Collateral Registries_ , IFC, January 2010, C. 1.  1.1 Capabilities of Government to Operate Registry, and Private Sector Alternatives, page 63.

> 25 In Egypt, the credit bureau (Iscore) is a private entity, and has been given the mandate to create and manage the collateral registry.

19