摘要:This paper starts with analysis why the U.S. sub-prime crisis had been caused, which mainly describes the inspiration of the U.S.
ards the long-term virtuous cycle track. In view of agency-based supervisory approach in the United States was a great success, it has quickly become the world's nations the best choice when to build the regulatory system.
4.3.2 Japan's administrative control mode
While Japan's financial regulatory practice, there are not several regulatory bodies’ coexistence, but its regulatory approach is still very different from the United Kingdom and U.S.A, the most prominent financial regulation in Japan attaches particular importance to the administrative authority of the Ministry of Finance. As the banking sector played an important role in promoting the development process of the Japanese economy, thus gradually formed a unique regulatory system which the Bank of Japan (the Central Bank) set monetary policy, and the Ministry of Finance set all other financial policy. As Japan's unique financial industry regulator, the Ministry of Finance, from the macro and micro levels to control the Japanese economy, leaves the supervision of the Central Bank of Japan very little space.
In the early process of managing the economy, Ministry of Finance achieved remarkable results, helping Japan's economy leap-forward development, has remained the world's second largest place of the economy, but with the financial markets appear increasingly complex, it became not flexible enough. Particularly in early 90’s of 20th century, the “compensation” scandal, as well as the largest securities firm--Nomura was also involved in the scandal, which making the voice to reform the Ministry of Finance and to manage the financial system grow ever louder. In June 1998, Japan has finally set up a single regulatory body - the Office of Financial Management, the agency enjoys formulating monetary policy, management of securities, derivatives, banking and other powers. However, from the Ministry of Finance to the Office of Financial Management, the Japanese government still followed the traditional regulation and control of economic; the power of administrative supervision is still very strong. On derivative financial transactions, Financial Management Office has the authority to keep check the financial background of banks and other financial institutions, to introduce derivative financial measures for internal risk management for derivatives markets, and to prevent and treat the illegal fraud incidents in derivative markets.
4.3.3 The British model of a single regulatory
British regulation of the financial derivatives is a single-system-regulatory approach; all regulations are carried out through the Financial Services Authority, which is the only financial markets regulatory body. In October 1997, the original SIB formally changed its name to the Financial Services Authority; it was fully responsible for the UK financial sector regulation (Ross Levine, 2006, Rethinking Bank Regulation (Till Angles Govern: Cambridge University Press)). According to “Financial Services Act”, the Financial Services Authority would not only absorb many of the existed self-regulatory organizations and other regulatory bodies into their own organization to take over its supervisory functions, but also, in June 1998 received the Bank of England’s banking supervision functions, insurance regulation functions as well as the review functions listed on the stock exchange, then the Financial Services Authority
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