证券市场交易行为的中外法律比较

本文以保护投资者利益为基础,对中外法律有关市场交易行为方面的内容及各方应承担的法律责任进行了比较,指出目前有关市场交易行为的立法上我国与外国差异不大,但在承担的法律责任上,我国由于缺少民事赔偿制度等具体措施,缺乏保护投资者利益的法律依据.通过比较本文提出了一些政策性建议:我国应在立法内容上明确具体的责任人,在法律责任中增加民事赔偿责任的具体条款.

The Comparation of the Law on Securities Market Transactions between China and Foreign Countries

Based on the protection of investors'profit, this paper compares the content about the market trade behavior and the Legal responsibility each aspect should take of Chinese law with that of foreign law. As this paper will shows there're not much difference between market trades, but as to the duties they should assume they are too lack. Because our country is short of civil compensation systems, how to protect investor'interests is out of law control. By compare the writer suggest: Definite the person in charge, add concrete clauses of civil compensation duties in legislations of China.