If we want to analyze the similarities and differences between the financial supervision systems in the United States and China, we must first understand the characteristics of the financial supervision systems in the United States and China, and then we can make a detailed and reasonable explanation.

At noon on June 17, 2009, the US government officially announced the most thorough comprehensive financial supervision reform plan since the Great Depression of June 1929, which was called the "White Paper" on the reform of the US financial supervision system. The blueprint for reform and the latest white paper will be analyzed below.

(A) the main contents of the blueprint for reform

The blueprint for modernization puts forward short-term, medium-term and long-term suggestions, among which the long-term proposal puts forward a new concept of target supervision to establish a three-pillar supervision system of market stability supervision, prudential supervision and financial market business behavior supervision to ensure the core position of the United States in the global financial market.

1. Short-term suggestions aimed at empowering and strengthening coordination. Short-term suggestions are mainly aimed at the current turmoil in the credit and mortgage markets. It is suggested that measures should be taken to strengthen the cooperation between regulatory authorities and market supervision, so as to promote the stability of financial markets and strengthen consumer protection. The specific contents include: First, improve the efficiency of the President's Financial Market Working Group (PWG) as the coordinating body of financial supervision policies. Office of the Commissioner of Currency (OCC), Federal Deposit Insurance Corporation (FDIC) and Office of Savings Supervision (OTS) were introduced into PWG as new members to expand its lineup, and PWG's focus expanded from the financial market to the whole financial system. Second, set up the Federal Mortgage Founding Committee, strengthen the supervision over the initiation of housing mortgage loans, and supervise the management of mortgage loans in various states, so as to change the situation that many such brokers are out of federal supervision at present. Third, give the Fed more right to know and review. Grant the Fed the right to ask for more information from all financial system participants (including commercial banks and non-commercial banks) who borrow emergency liquidity or conduct on-site inspections, and assess the impact of financial institutions' liquidity and related activities on overall financial stability.

2. Mid-term proposal for the purpose of partial integration of regulatory agencies. On the basis of short-term suggestions, the blueprint puts forward some medium-term suggestions to reduce the overlap of American supervision and improve the effectiveness of financial supervision, some of which can be implemented as soon as possible under the existing regulatory framework. Specifically, it includes five aspects: first, it is suggested to cancel the license of the federal savings institution and incorporate it into the license system of the national bank, which will be completed within two years; The abolition of the Savings Management Bureau, its original duties are performed by the Monetary Audit Bureau, which has the power of national banking supervision. Secondly, in view of the dual supervision of the state-registered federal deposit insurance banks by the state government and the federal government, it is suggested that the state-registered banks be supervised by the Federal Reserve or the Federal Deposit Insurance Corporation. Third, in the supervision of payment and settlement systems, federal concessions and federal priorities for important payment and settlement systems should be established. The Federal Reserve bears the main responsibility for supervising such systems, and enjoys important free decision-making power and the power to formulate relevant mandatory standards. Fourthly, in the insurance industry, the state regulatory authorities have always been responsible for supervision, and the federal government has only supervised the insurance business, resulting in the American insurance giant, American International Group (AIG), on the verge of bankruptcy due to the creation and holding of a large number of CDS. Fifth, merge the Commodity Futures Trading Commission and the Securities and Exchange Commission, and the Securities and Exchange Commission will supervise the securities and futures industry in a unified way to improve the inefficiency of separate supervision of securities and futures in the past.

3. Long-term suggestions for the purpose of establishing a targeted supervision model. Blueprint proposal: First of all, the Federal Reserve should perform its duties as a market stability regulator, with the goal of ensuring the stability of financial markets and focusing on controlling systemic risks. Second, a prudent financial supervision institution should be set up to integrate the power of banking supervision, and the daily banking supervision affairs currently handled by five federal agencies should be handed over to the prudent financial supervision institution for unified responsibility. Its supervision focuses on the daily business operations of financial institutions with government guarantees, monitoring their capital adequacy ratio, investment restrictions, activity restrictions and other matters, and conducting necessary on-site inspections. Third, set up a new business behavior supervision institution to supervise business behavior and protect the rights and interests of investors and consumers (mainly the main functions of the existing commodity futures trading commission and securities trading commission and some functions of banking supervision institutions). In addition, a federal insurance guarantor and a corporate financing supervisor have been established.

From this point of view, the blueprint reorganizes and classifies the existing multi-functional regulatory system, realizing the close combination of three regulatory objectives and three levels of regulatory agencies, aiming at improving regulatory efficiency, maintaining financial stability, better protecting the rights and interests of investors and consumers, and improving the competitiveness of the United States in the global capital market. Moreover, through the introduction of the blueprint, we can also see that the reform of the blueprint is to improve supervision rather than simply increase supervision and intervention, and has not given up the concept of relying entirely on market discipline, but to rebalance the relationship between supervision and market under the new financial market development background.

(B) The latest achievement of financial supervision system reform: White Paper

At noon on June 17, 2009, the US government officially announced the most thorough comprehensive financial supervision reform plan since the Great Depression of June 1929, which was called the "White Paper" on the reform of the US financial supervision system. This 88-page reform plan covers almost all aspects of the US financial industry, from stricter consumer protection policies to stricter regulatory rules for financial products. This plan puts financial products and financial institutions that are currently out of supervision under the control of the federal government. The purpose of the reform is to comprehensively repair the existing financial supervision system in the United States and prevent the recurrence of the current crisis.

First, strengthen the supervision of financial institutions. The white paper points out that all financial institutions that may bring serious risks to the financial system must be strictly supervised. To this end, the government will implement the following six reforms: the establishment of a financial services regulatory Committee led by the US Treasury Department to monitor systemic risks; Strengthen the power of the Fed, authorize the Fed to solve the problem of risk accumulation that threatens the whole system, and expand the scope of supervision to all enterprises that may pose a threat to financial stability. In addition to bank holding companies, hedge funds and insurance companies will also be included in the supervision of the Federal Reserve; More stringent capital and other standards will be set for financial enterprises, and higher standards will be set for large and highly related enterprises. The Federal Reserve has the final decision on the capital requirements of banks, and the right to monitor the executive compensation and financial market trading system of these companies will be included in the scope of the Federal Reserve; Establish a national banking supervision institution to supervise all banks with federal licenses; Cancel the savings administration and other institutions that may lead to regulatory loopholes to avoid some deposit-taking institutions from evading supervision; Hedge funds and other private equity institutions need to register with the US Securities and Exchange Commission.

Secondly, establish all-round financial market supervision. The white paper suggests that the supervision of the securitization market should be strengthened, including increasing market transparency and strengthening the management of credit rating agencies, and promoters and issuers should bear certain risk responsibilities in related credit securitization products. Comprehensively supervise the over-the-counter trading of financial derivatives, and expand the scope of federal supervision to the gray area of financial market supervision. Complex derivatives transactions and mortgage-backed securities transactions will be placed under supervision, among which strengthening hedge funds and over-the-counter market (OTC) is the most typical. Give the Federal Reserve the power to supervise the payment, settlement and clearing system in financial markets.

Third, protect consumers and investors from improper financial behavior. The white paper points out that in order to rebuild confidence in financial markets, strict and coordinated supervision of consumer financial services and investment markets is needed. The government must make this market transparent, simple, fair, responsible and open. To this end, the white paper proposes to set up a consumer financial protection bureau to protect consumers from unfair and fraudulent acts in the financial system, strengthen supervision over financial products and services of consumers and investors, and promote the transparency, fairness and rationality of these products. Improve the industry standards of consumer financial products and service providers, promote fair competition, and protect the interests of consumers of financial products such as mortgages and credit cards.

Fourth, give the government the necessary policy tools to deal with the financial crisis, and avoid the dilemma of whether the government should rescue the enterprises in difficulty or let them go bankrupt. Establish a new mechanism for the government to decide how to deal with non-bank financial institutions that are in crisis and may bring systemic risks. The government has the right to take over and split large financial companies in trouble, so as to avoid the collapse of individuals endangering the overall economy, which the government lacked during the worst financial crisis last year. In addition, the Federal Reserve needs the approval of the Ministry of Finance before providing emergency financial assistance to enterprises.

Fifth, establish international regulatory standards and promote international cooperation. To this end, the white paper proposes to reform the enterprise capital framework, strengthen the supervision of international financial markets, strengthen the cooperative supervision of multinational enterprises, and coordinate the policies of various countries in order to create a compatible regulatory framework and strengthen the ability to cope with international crises. Specific measures include formulating similar regulations on the supervision of credit derivatives, signing cross-border agreements on the supervision of large multinational financial institutions, and better cooperation with overseas regulatory agencies.

The financial regulatory reform plan considers the financial industry as a whole for the first time, which is the largest financial regulatory reform in the United States since the 1930s. However, it is worth pointing out that compared with the Blueprint for the Reform of Modern Financial Regulatory Structure published by US Treasury Secretary Paulson on March 3 1 2008, the White Paper continues the spirit of the Blueprint for the Reform of Modern Financial Regulatory Structure, greatly expands the power of the Federal Reserve, brings banks and hedge funds into the scope of the Fed's supervision, and cancels the Federal Agency for the Supervision of Savings and Loans-the Savings Administration. However, there is also a considerable degree of shrinkage. For example, the government initially planned to integrate regulators and set up a single institution to supervise the banking industry, but eventually chose to strengthen the power of the Federal Reserve within the existing structure.

In short, through the above analysis of the contents and reasons of the reform of the financial system in the United States, we can see that the United States has begun to move from the current multi-functional supervision model to a more centralized and targeted supervision model. The path and thinking of this reform can be said to be completely in line with the development trend of international financial supervision, that is, the trend of centralized supervision.

(3) Evaluation of target supervision mode in reform blueprint-comparison with functional supervision mode.

From 65438 to 0999, the passage of the Financial Services Modernization Act in the United States completely ended the state of separate operation of banks, securities and insurance, marking the beginning of mixed operation in the United States. Accordingly, the concept of financial supervision in the United States has also changed from institutional supervision to functional supervision. Although the concept of functional supervision has jumped out of the shortage that institutional supervision belongs to financial institutions under the condition of separate operation, the functional supervision system in the United States has promoted functional coordination, information communication and law enforcement cooperation among various regulatory agencies without touching the existing supervision system, and is still a model of separate supervision in essence, without providing clear system construction and authorization support. Therefore, in the course of ten years' operation, the disadvantages of the financial supervision system have been gradually exposed and broke out in this crisis. Mainly manifested in the following aspects: First, there is a lack of an institution that can have all regulatory information and guard against regulatory systemic risks. Second, different regulatory agencies apply different regulatory legal rules and use different regulatory concepts. This provides space for some financial institutions to carry out regulatory arbitrage, which leads some institutions to actively choose the most favorable regulatory agencies. Third, multi-level regulatory agencies and multi-standard regulatory operations will inevitably lead to overlapping regulatory work. This overlapping of supervision increases the cost of supervision.

Compared with the defects of functional supervision, the advantages of targeted supervision mode are mainly reflected in the following points:

First of all, we can improve the efficiency of supervision by integrating regulatory agencies and regulatory forces. In view of the inefficiency caused by the lack of supervision and overlapping supervision exposed in the subprime mortgage crisis, the blueprint for reform puts forward the target supervision orientation in order to better deal with various problems in the practice of financial supervision and give full play to the joint efforts of various regulatory agencies. The directional supervision mode has broken the mode of separate supervision of banking, insurance, securities and futures. According to different regulatory objectives and risk types, regulatory agencies are divided into three systems: market stability regulatory agencies, prudent financial regulatory agencies and business conduct regulatory agencies. The close combination of the three systems not only avoids the emergence of regulatory loopholes and overlaps, but also enables regulators to adopt unified regulatory standards for the same financial products and risks, which will greatly improve regulatory efficiency. This integration of regulatory agencies reflects a trend from decentralization to centralization, and centralization will inevitably improve the efficiency of supervision.

Second, the targeted regulatory model can better cope with the regulatory gap brought about by financial innovation. The lag of financial supervision determines that it is impossible to cope with the ever-changing changes in the financial market simply by formulating regulatory rules. With the deepening of financial innovation, it is impossible to catch up with the speed of innovation only through the formulation of specific rules. Second, financial innovation constantly breaks through the restrictions of rules, leading to the blank of supervision. The subprime mortgage crisis is the best illustration. In the face of the subprime mortgage being constantly packaged and reorganized to create new derivatives, regulators could not be uniformly supervised by one institution according to the inherent rules, which led to the accumulation of risks in different financial systems and finally detonated the subprime mortgage crisis. However, targeted supervision is not limited to formulating specific regulatory rules. Starting from the whole financial system, it integrates the stability of the financial system, prudent operation of financial institutions and consumer protection into three major goals, and builds an efficient and unified supervision department. In this way, the risks arising from the whole chain of financial innovation will be covered, and there will be no regulatory gap.

Thirdly, the proposed directional supervision has one of the biggest benefits, that is, it jumps out of the debate on separate supervision mode or mixed supervision mode, and can be compatible with both supervision modes. The blueprint for reform reconfirms the important objectives of financial market supervision, and puts forward three major objectives of maintaining financial market stability and security: financial market stability, prudent operation of financial institutions and protection of financial consumers. In order to achieve these regulatory objectives, a single regulatory agency can implement "mixed supervision", but in theory, it does not rule out that financial regulatory agencies in different industries should "separate supervision", which requires specific design because the timing and national conditions are different. For example, in the blueprint of this reform, the regulation of financial market stability emphasizes the need to expand the power of the Federal Reserve as the regulator of market stability. In addition to supervising commercial banks, it will also have the right to supervise investment banks, hedge funds and other financial institutions that may bring risks to the financial system. This is the choice of comprehensive and unified supervision determined by the current situation of financial mixed operation in the United States. Similarly, if a country has always had a tradition of separate supervision, it can also consider maintaining the original separate supervision model under any regulatory objectives.

Second, the enlightenment of the reform of American financial supervision system to China.

Through the above analysis of the reform of financial supervision system in the United States and the trend of centralization of international financial supervision, it can be seen that all major developed countries are gradually integrating the number of financial supervision institutions and gradually moving closer to the single-headed or double-headed supervision model. Combined with the current situation of the development of China's financial supervision system, the author believes that China should establish a unified financial supervision system for the following reasons:

First of all, as a late-developing country, China can establish a unified financial supervision system in one step. Throughout the development history of the financial industry in major developed countries in the west, financial management has experienced the historical repetition of mixed operation, separate operation and mixed operation. For example, in the United States, 19 allowed banks to operate in mixed operation at the end of the year, and the glass-steagall act of 1933 prohibited commercial banks from underwriting corporate securities or engaging in brokerage business, and prohibited investment banks from engaging in commercial banking activities, thus establishing separate operation. With the promulgation of 1999 "Financial Services Modernization Act", the financial mixed operation that lasted for nearly a century was finally restored. Since 1980s, major developed countries in the world have abandoned the separate operation mode and established the mixed operation mode. This change in financial management mode directly led to the reform of financial supervision system. Many countries have carried out drastic reforms on the original financial supervision system, and merged financial supervision institutions to form single-headed or double-headed supervision institutions, thus forming a centralized supervision system. The reform of the financial supervision system in the United States is also aimed at integrating the existing multi-head supervision institutions and making them more efficient in preventing systemic risks. The historic changes in financial management in developed countries have made them embark on the road of seeking centralized supervision. As a late-developing country, China has not experienced the over-prosperous financial development of western developed countries. China's financial industry is still in its infancy, its financial market is still far from perfect, and its financial products are still underdeveloped. Drawing lessons from the experience of western developed countries, China can establish a unified supervision system in one step. In this way, the crisis-driven characteristics of financial supervision lagging behind financial innovation can be avoided to a certain extent, and China's financial supervision system can be forward-looking and better cope with the changes in the ever-changing financial market.

Second, the current development of China's financial mixed operation needs a unified supervision system. In fact, since 1994, the professional division of labor of national banks has been cancelled and the process of financial business integration has begun to advance. In practice, under the background of rapid development of international financial industry and great competition pressure at home and abroad, the relationship between banks, securities and insurance in China has been strengthened continuously, and the situation of mutual doping and infiltration of financial services has gradually formed, and the phenomenon of mutual shareholding of financial institutions has gradually increased, and the financial industry has shown a development trend of comprehensive management. In fact, financial holding companies with group, bank holding mode and industrial enterprise holding mode have emerged. Financial innovation has gone beyond the corresponding laws, regulations and supervision scope, and a separate supervision system has been put forward.

Third, the establishment of centralized and unified financial supervision institutions is in line with the policy orientation of establishing a large-scale system to save administrative resources in China. At present, China is implementing the small sector system. The Ministry system is a comprehensive management organization system of government affairs, which is characterized by "large functions, wide fields and few institutions". Government departments have a wide range of management and comprehensive functions. According to the spirit of the 17th National Congress of the Communist Party of China, the reform of the "Ministry system" is the need to improve the socialist market economic system and deepen the reform of the social management system, which has important practical significance. However, the reform of the Ministry system will not be achieved in one step, and a consensus has basically been reached on gradual progress. At present, the pilot scope of the Ministry system will be selected from three aspects: first, some functional combinations of the so-called big agriculture, agriculture, forestry, animal husbandry and fishery and the Ministry of Water Resources; The second is the adjustment and merger of the system of the commission of science, technology and industry for national defense; The third is big traffic, which mainly involves the Ministry of Communications, the Ministry of Railways and the Civil Aviation Administration. Although the reform of the Ministry system in the field of financial supervision has not been put on the agenda, it is in line with the value orientation of the reform of the Ministry system to establish a unified financial supervision institution outside the People's Bank of China to supervise the whole financial industry. Therefore, in the future, China Banking Regulatory Commission, China Insurance Regulatory Commission and China Securities Regulatory Commission should be merged to form a financial supervision committee independent of the People's Bank of China, which is only responsible for the formulation of monetary policy and macro-control of the financial industry, and no longer has the function of financial supervision. This can not only avoid the overlapping functions of the three departments in specific financial supervision, but also prevent the regulatory gap caused by the ever-changing financial innovative products and improve the efficiency of financial supervision.

Fourth, learn from East Asian countries and establish a unified financial supervision system. From 65438 to 0997, a financial crisis that started in Thailand quickly spread to the whole of Southeast Asia and the whole world, causing the stock exchanges and stock markets in many countries and regions in Southeast Asia to plummet one after another, causing serious trauma to the financial system and even the whole social economy. After the crisis, from 65438 to 0998, the Japanese government carried out two major reforms to the financial supervision system: first, it set up an independent financial supervision institution, separated the banking bureau from the financial supervision department, the financial inspection department and the securities trading supervision Committee of the securities bureau from the Ministry of Finance, and set up the financial supervision institution as the foreign affairs bureau of the Prime Minister's Office-the financial supervision office (later renamed as the financial supervision office), which became the institution responsible for financial supervision affairs. Another reform is to strengthen the independence of the central bank in implementing monetary policy. South Korea, another badly hit country in East Asia, established a single financial supervision institution, namely the Financial Supervision Committee, in April 1998 with the financial assistance and influence of the International Monetary Fund. It can be seen that after the Asian financial crisis, East Asian countries such as Japan and South Korea established unified financial supervision institutions and implemented comprehensive supervision, which played a certain role in effectively preventing systemic risks in the financial industry. It can be said that the economic rise of Japan and South Korea after the Asian financial crisis is closely related to the prosperity of the financial industry brought about by the financial regulatory reform. Although China did not suffer heavy losses in the Asian financial crisis and achieved a soft landing, these experiences and lessons of East Asian countries are worth learning from. Combined with the actual situation of China's financial supervision, it is our inevitable choice to establish a unified financial supervision system.

And what is the current financial supervision system in China? The situation is as follows:

The basic feature of the current financial supervision system in China is separate supervision. In recent years, with the rapid development of financial globalization, liberalization and financial innovation, it is an irreversible trend for financial institutions to implement mixed operation. The separate supervision system has shown obvious inadaptability and its own inherent problems have gradually emerged. Therefore, it is imperative to reform the financial supervision system, strengthen financial supervision, guard against financial risks and improve supervision efficiency.

Financial supervision is a general term for a country's financial supervision authorities to supervise and manage banks and other financial institutions and their financial activities in accordance with laws and regulations in order to achieve macroeconomic and financial goals. As a financial system arrangement provided by the government to correct market failure, it aims to maximize the efficiency and stability of the financial system. A country's financial supervision system is fundamentally determined by its own political and economic system and financial development. The key to judge whether a country's financial supervision system is effective lies in whether it can ensure the safe operation of its financial system and adapt to the development level of its financial industry.

Challenges and problems faced by the current financial supervision system

The construction of China's financial supervision system can be roughly divided into two stages: the first stage is the unified implementation of financial supervision by the People's Bank of China before 1998; In the second stage, starting from 1998, the supervision of securities industry and insurance industry was separated from the unified supervision of the People's Bank of China, and they were respectively under the responsibility of the China Securities Regulatory Commission and the China Insurance Regulatory Commission, forming a pattern of separate supervision of the People's Bank of China, the China Securities Regulatory Commission and the China Insurance Regulatory Commission. In 2003, the China Banking Regulatory Commission was formally established and took over the banking supervision function of the People's Bank of China. As a result, China has formally established a financial supervision system with separate operation, separate supervision and division of labor among the three associations.

The basic feature of the current financial supervision system in China is separate supervision. According to the division of financial supervision, the CBRC is mainly responsible for the supervision of commercial banks, policy banks, foreign banks, rural cooperative banks (credit cooperatives), trust and investment companies, finance companies, leasing companies and financial asset management companies. Taking the big banking industry as the caliber, the CBRC has set up a supervision department, a cooperative financial supervision department and a non-bank financial institution supervision department, with corresponding provincial bureaus, municipal branches and counties (cities) from top to bottom. The CSRC and the CIRC are respectively responsible for the supervision of securities, futures, funds and insurance; Corresponding supervision departments and offices have been set up internally, and corresponding bureau (province, city and city with separate plans) systems have been established from top to bottom. After the establishment of the CBRC, the People's Bank of China made great efforts to strengthen the formulation and implementation of monetary policies, be responsible for the payment safety of the financial system, and give play to the functions of the central bank in macro-control and prevention of financial risks. This organizational structure of financial supervision shows that, except the central bank is responsible for macro-control, several other regulatory agencies focus on the micro-regulatory level of related industries. The biggest advantage of choosing this supervision system is to improve the professional level of supervision, realize the supervision objectives in time and improve the efficiency of "institutional supervision".

As far as China's current financial supervision system is concerned, the achievements made since its actual operation are generally worthy of recognition. It not only unifies the regulatory framework, strengthens the specialization of supervision and improves the efficiency of supervision, but also helps the central bank to formulate and implement monetary policy more effectively. However, in recent years, with the rapid development of financial globalization, liberalization and financial innovation, the pace of opening up the financial industry has accelerated, and the financial supervision environment has undergone major changes. The separate supervision system has shown obvious inadaptability, and its own inherent problems have gradually emerged.

It can be seen that China's current financial supervision system is based on China's current basic national conditions, starting from the overall social situation, and building a benign financial supervision system in harmony to ensure the stable development of China's economy and serve various social undertakings. Unlike the United States, it is formulated from a political perspective and according to the operation of the capital market.