Oct 26, 2000 10:21
24 yrs ago
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German term

ppa.

German to English Bus/Financial Law: Contract(s)
ppa. (per procuram) in front of a signature means that the person has the commercial power of attorney (there isn't an equivalent in English for "Prokura"). But does anyone know how to translate the abbreviation in a contract? Thanks for your help.
Change log

Apr 24, 2006 19:37: Steffen Walter changed "Field (specific)" from "(none)" to "Law: Contract(s)"

Proposed translations

3 hrs
Selected

no answer is also an answer

My Pons Fachwörterbuch Recht and NODE show "per pro" = "pp" = "PER PROCURATIONEM" (NODE also mentions "Procuration"), both BE, but I do not think the modern sense is quite the same as "p.pa." in Germany. Neither term is in my Webster's. NODE and Pons give more or less the meaning for "per pro" that Trudy mentioned. I have always thought that "for"(AE), "on behalf of"(AE&BE) or "per pro"(BE) were similar to the German "i. A." = "im Auftrag". "im Auftrag" = i. A." is probably closest to "pp" (BE), in other words the signer usually only has the authority to sign a particular document or type of document and is mostly used for everyday letters.


Neither NODE or Pons mention the German Prokurist's real authority to negotiate, act and deal for the business when discussing "per pro". Leipzig's answer "Authorized Officer" sounds better to me (as an American) for a real German Prokurist because the term "per proxy" again only conveys the connotation of voting or marriage and also people feel that the proxy is only a sort of messenger with the power to act in one specific, cut-and-dried, limited function. A modern German "Prokurist" normally has considerable, flexible authority and responsibility, similar to a corporate officer.

The problem still remains: what does someone in the UK call a company official with the power, authority and responsibility of a German Prokurist (p.pa.) and what should be written at the bottom of an important contract where he signs?

I'm sure this has only made matters worse, sorry - Dan

P.S. – Langenscheidt shows two German abbreviations for "PER PROCURATIONEM": - ppa. and p.pa.
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4 KudoZ points awarded for this answer. Comment: "Thank you to all of you. You provided such long answers and explanations. I think we can all more or less agree that there is no adequate rendering of "ppa/Prokurist" in English. So, I decided to make a footnote and explain the whole thing to the client. "
50 mins

per proxy

This is per proxy which can also be abbreviated with pp or p.p. (According to Black's Law Dictionary. Even though there is no real equivalent, Prokura can be rendered an authorized officer, at least in American English.

Good luck!
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+1
51 mins

signed for or on behalf of

That's how I usually translate this. It means the person signing the document on behalf of someone else has signature rights.

Peer comment(s):

Dan McCrosky (X)
agree Daniel Trujillo : Agree. In Colombia we use the phrase "por poder" meaning that the signatory was acting on behalf of someone else and that renders the actual signature valid and binding.
7447 days
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2 hrs

per procuration

Per Schäfer, Wirtschaftsenglisch, this would be "per procuration".
See also the following:
If someone negotiates a physician's checks under a power of attorney, he/she typically prints the physician's name on the back of the check and enters his/her signature below, followed by "p.p." or "p.p.a." (for per procuration, per power of attorney, or power of attorney).
www.aamc.org/private/deans/afad/deanmemo/dm1999/99_48.htm


ppa.
(com) = per procuram
per procuration
(com) per Prokura, ppa. (ie, abbreviated: per pro)
per pro signature
(com) Prokura-Unterschrift f (eg, XY Bank, per pro John Doe)

HTH.
Peer comment(s):

Beth Kantus
Wolfgang Tiefert
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3 hrs

concur with uel's answer

see also Dietl/Lorenz Dictionary of Commercial, Legal, and Political Terms
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20 hrs

more definitions

Here's some more information to thicken the soup:
According to DIN 5008 (Aufbau eines Geschäftsbriefes),
i.A. (im Auftrag) bezeichnet Einzelvollmacht, d.h. die Mitarbeiter/in, der/die unterschreibt ist in diesem einzelnen Fall dazu berechtigt.
i.V. (in Vollmacht, in Vertretung). Der/die Unterschreibende ist zu mehreren Rechtsgeschäften auf unbeschränkte Zeit berechtigt.
ppa. (per procura). Der/die Unterschreibende besitzt Prokura.

Bei mehreren Unterschriften steht die der/des Ranghöheren links.

I found the following definitions in West's Law & Commercial Dictionary in Five Languages:
Per procuration (per proc./, p.p.) By proxy; by one acting as an agent with special powers, as under a letter of attorney. These words give notice to all persons that the agent is acting under a special and limited authority. The phrase is commonly abbrerviated to per proc., or p.p. and is more used in the civil law and in England than in American law. A proxy or signature of a principal executed by an agent who discloses his role as agent on the document.
German: in Vollmacht, in Vertretung, (per) Prokura (Wertpapierzeichnung)

Procuration - Agency; proxy; the act of constituting another one's attorney in fact. The act by which one person gives power to another to act in his place, as he could do himself. Action under a power of attorney or other constitution of agency. Indorsing a bill or note "by procuration" is doing it as proxy for another or by his authority. The use of the word procuration (usually, per procuratione, or abbreviated to per proc. or p.p.) on a promissory note by an agent is notice that the agent has but a limited authority to sign.
German: Besorgung, Verschaffung, Vollmacht, Prokura, Stellvertretung.

Agency - Relation in which one person acts for or represents another by latter's authority ... The relation created by express or implied contract or by law, whereby one party delegates the transaction of some lawful business with more or less discretionary power to another ...
See also ...General agency, ...
German: Stellvertretung, Beveollmächtigung, Auftragsverhältnis

General agency - An agency which exists when there is a delegation to do all acts connected with a particular trade, business, or employment. It implies authority on the part of the agent to act without restriction or qualification in all matters relating to the business of his principal.
German: Generalvertretung, Prokura, Handlungsvollmacht.

General agent - one who is authorized to act for his principal in all matters concerning particular business or employment of particular nature.
German: allgemeiner Bevollmächtigter, Handlungsbevollmächtigter, Generalvertreter.

Handlungsvollmacht - Ger. commercial proxy; this proxy power may be given by any merchant and need not be explicit (e.g. by acquiescence). The commercial proxy is not entered in the commercial register. Signatures by a commercial proxy are customarily followed by the abbreviation i.V. ("in Vertretung").
German: Generalhandlungsvollmacht, Spezialhandlungsvollmacht, Anhandlungsvollmacht.

That's a lot of definitions. It would seem that the term general agent would most closely fit Prokurist in the sense as defined by Dan in his answer. But Prokurists are, to my knowledge, listed in the commercial registry.
Hope this helps more than it confuses! - Beth
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1 day 51 mins

more on agents and agency

Please correct me if I am wrong, but as far as I know, an agent, general agency, or general agent is by definition never an employee of her/his principal. Additionally, as far as I know, a Prokurist is always an employee of his employer (the person Who grants the Procura). If the two preceding sentences are correct then a Prokurist cannot be any sort of agent.

Margit - this is quite an important subject, please do not let Henry or Troy bulldoze you into grading the question till someone comes up with a really good answer. - Dan
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