3. REGULATORY I N T E N S I TY

Universality not only indicates that the law of the forum governs the effects of

insolvency on entitlements irrespective of the law under which these entitlements have

come into existence, but also that the law applies extra-territorially, i.e. irrespective

of where the asset or liability is located. In addition to a legitimate interest, for universality

to be justified these two elements must also be shown to be necessary and appropriate.