Financial Regulatory Modernization: Experiences and Lessons from Common Law Jurisdictions

The aim of this article is to examine the financial regulatory regimes in common law jurisdictions and based upon the results of such examination, set out reform proposals for China. The reforms undertaken in common law countries, including the US, the UK and Australia, are discussed and sorted into three models, namely the US 'multi-regulators model', the UK 'single-regulator model' and the Australian 'twin peaks model'. It is submitted that the US model can be used in the short term, and with the further growth of China's financial markets, the long-term solution should be the Australian model and to a lesser extent the UK model.