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of an administrator by the charge holder), or by the company itself (if the company isinsolvent, or the directors are concerned about becoming personally liable forwrongful trading).The primary English insolvency proceedings are:• liquidation (compulsory by the Court or voluntarily by the company),• voluntary arrangement (a statutory scheme of debt compromiseapproved by the majority of creditors in value), or• administration (a procedure aimed at rescuing the company with theaid of a moratorium).2. Initiating the insolvency proceedingsa. GermanyThe insolvent company itself or, under certain conditions, any creditor of theinsolvent company is entitled to file an insolvency proceeding with the InsolvencyCourt. 13 b. FranceThe insolvency proceeding (redressement judiciaire or liquidation judiciaire) may beopened upon request of the company itself, a creditor, or the public prosecutor.The pre-insolvency proceeding (mandat ad hoc, conciliation, sauvegarde) may onlybe opened upon request of the company.over specific assets. A qualifying floating charge is created by a security agreement or otherdocument that clearly states either that paragraph 14 of Schedule B1 of the Insolvency Act of 1986applies to the floating charge, or that otherwise states that the holder of the charge is authorized toappoint an andministrator or administrative receiver under the Insolvency Act.13 Insolvenzordnung [InsO] [Insolvency Statute], Oct. 5, 1994 [Bundesgesetzblatt] (BGBl.] 2866, aslast amended by Art. 6 G of the Act of August 31, 2013 [BGBl.], 3533, § 13.10