英国法上的浮动抵押制度经过长期的发展,已经形成一套完整的担保制度。但在其实际运行过程中,浮动抵押的财产范围、抵押权人的范围、设立生效模式都存在一定的争议,这也导致了现实运行中困局的产生,本文旨在初探英国法上该制度的兴革困弊,启发进一步研究。 After a long period of development, the floating mortgage system in the UK law has formed a complete set of guarantee system. However, during its actual operation, the scope of the property of floating mortgage, the scope of the mortgagee, and the establishment of effective mode have some controversy, which also leads to the emergence of the dilemma in the real operation. The purpose of this paper is to explore the system of the British law The pros and cons of the reform, inspired further study.