Članstvo korisnika i investitora u zadruzi: Uporedni pregled uređenja u Evropskom privrednom prostoru i SAD
Patron and Nonpatron (Investor) Members in Cooperatives: A Comparative Survey of the Regulation in the European Economic Area and in the USA

Summary/Abstract: The paper deals with a comparative analysis of membership regulation in the recent cooperative legislations within the European Economic Area (EEA) and in the United States of America (USA). In EEA, cooperatives can be established according to the national cooperative law or on the basis of supranational model of the European Co-operative Society (Societas Cooperativa Europaea, SCE), the general cooperative law in the USA is, in principle (if federal chartered credit unions are left out of account), encompassed by the legislative competence of individual States. In order to consolidate the equity base of cooperatives, recent provisions about cooperatives often allow cooperatives to admit as members not only users of their services (user-members or patron-members), but also persons, who have, exclusively on the basis of capital investment, certain property and governance rights (so called investor members or non-patron members). While the SCE Regulation refers, as far as the investor members are concerned, to national cooperative legislation of the Member State according to the registered office of SCE, investor membership is, as an alternative source of equity, regulated more in detail by the American Uniform Limited Cooperative Association Act, adopted in 2007.

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