Comparative Analysis of Foreign Experience of Registration Systems and the Possibility of Implementing Some Elements into the Russian Registration System

The paper analyzes foreign real estate registration systems (Germany, France, USA, Australia), analyzes them from the standpoint of ease of use and protection of the purchaser. The author examines the shortcomings of the modern Russian registration system and proposes solutions using the available foreign experience. The author analyzes models of real estate registration using economic cognitive structures in order to find such a system that would be as convenient as possible to use and at the same time does not require high costs and protects the rights of the purchaser. The paper also analyzes the relevant acts of the Constitutional Court of the Russian Federation, the Supreme Court, and the Supreme Arbitration Court using both legal and economic logic. The paper criticizes the existing judicial practice due to a too formal approach to the consideration of cases since low-quality court decisions also damage the credibility of the registration system. The author proposes several options for reforming the registration system, including the introduction of compulsory notarization of real estate transactions, the introduction of a compensation center, a "period of irrevocability".