1. The overall characteristics of the British trust system should be said that the British trust system is deeply influenced by traditional factors, so it is reflected in its own characteristics:

(1) Land trust business is widespread. Because the trust business in Britain originated from civil trust, and the trust property entrusted in civil trust is mainly real estate such as land, so the real estate trust such as land in Britain is more common than other countries. However, at present, due to the economic progress, the land trust in Britain has changed from the problem of the rights and interests of land trust property in the past to the purpose of operating profit and social and economic progress.

(2) Personal trust business is the main business. It should be said that the most striking feature of British trust business compared with other countries is that British trust business focuses on personal trust, because the traditional habit of Britain is that the content of trust is mostly civil trust and public trust, and the subject matter of trust is mainly real estate such as houses and land. Therefore, in terms of trustees, the business volume borne by individuals accounts for more than 8%, while that entrusted by legal persons is less than 2%.

(3) the corporate trust business is centralized. Although the proportion of trust business entrusted by British legal persons is not large, the British trust industry is concentrated in the trust departments (enterprises) set up by four major banks, such as National Westminster Bank, Barclays Bank, Midland Bank and Lloyds Bank, which account for 9% of all the trust assets of British legal persons. In addition, the insurance enterprise industry also runs part of the trust business.

2. General characteristics of American trust system

Theoretically, the level of trust industry in a country is closely related to its economic progress, and the trust industry in the United States always serves the needs of American economic progress:

(1) The United States is a typical country in the world where trust business is run by banks. One of the outstanding business characteristics of the United States is the extensive development of bank trust, that is, commercial banks are allowed to start trust business while operating banking business. At present, most commercial banks have set up their own trust departments to engage in trust business, and trust business in the United States is basically monopolized by trust departments set up by large commercial banks. At the same time, in the financial system of the United States, trust institutions enjoy the same status as commercial banks, and most trust enterprises have also joined the federal reserve system.

(2) Trust business and banking business in the United States are independent of each other within commercial banks. It is worth pointing out that although most trust businesses in the United States are run by banks, they are strictly distinguished according to their responsibilities, that is, the principle of "separation of functions, separate accounting, separate management, and dividend distribution (that is, dividend distribution on trust investment performance)" is implemented. On the one hand, strict qualification management is carried out for trust practitioners, on the other hand, people engaged in banking business are forbidden to act as trustees or * * * with trustees, so as to prevent illegal acts of trust parties.

(3) In the property structure of American trust industry, marketable securities are the key investment objects. The trust industry in the United States still takes securities as the critical trust object. In 199, among the trust properties in the United States, the proportion of common stock investment alone reached 48%, corporate bonds accounted for 21%, national debt and local government bonds accounted for 18%, and other trust properties accounted for about 13%. This is also determined by the specific national conditions of the United States, which is one of the countries with the most developed securities industry in the world. According to American laws and regulations, commercial banks are not allowed to directly deal in buying and selling securities and participate in enterprises. Therefore, in order to avoid these legal restrictions, banks mostly set up securities trust departments to act as securities agents, serving both securities issuers and securities buyers and holders. In this way, the trust industry in the United States also has the characteristics of extensive securities business.

(4) Trust property is highly concentrated. It should be said that the trust industry in the United States has basically been monopolized by the trust departments set up by domestic commercial banks, especially large commercial banks, and there are few professional trust enterprises. At present, the trust property managed by the top 1 big banks in the United States accounts for about 8% of the trust property in the whole United States, which is in an indisputable monopoly position.

3. The overall characteristics of Japan's trust system Japan is also one of the countries with faster speed and better effect in the development of trust system in the world today. Its characteristics include:

(1) Strictly implementing the separate operation of banks, securities and trust industries. Through various laws and administrative regulations, the Japanese government has put forward strict separation requirements for the business scope of trust enterprises. Except for seven trust banks and three commercial banks, other banks are not allowed to engage in trust business, and trust banks that concurrently engage in banking business are limited to the scope related to trust. In the specific business operation, the trust industry in Japan has also established its important position in the long-term financial field according to the principle of "separation of long-term and short-term finance" of the government, taking advantage of the fact that most of Japan's trust property is long-term stable property, and has become an urgent practitioner in the long-term financial business field with long-term credit banks.

(2) oligopoly industry market structure. With the two legal norms in 1922 and 1943, the operating institutions of Japanese trust industry have been sharply concentrated. After 195, due to the government's strict examination and approval of the trust industry, Japan's trust industry has been concentrated in the hands of seven critical trust banks. In recent years, with the continuous economic and financial depression in Japan, the trust industry in Japan has been continuously merged and reorganized, and there is a trend of further concentration.

(3) pay attention to innovation in combination with national conditions. The development of Japanese financial trust business pays more attention to innovation in combination with national conditions. For example, Japanese people have a strong family concept, so Japanese financial trust business has made great efforts to develop financial trust from the beginning. In addition, in order to create more favorable savings, property formation trust, annuity trust, employee stock ownership trust and specific gift trust were improved in 1981 to adapt to the people's choice of interest, which made Japan's trust business have the characteristics of wide scope, many types, flexible methods and active management.