| The world has been through serious financial crisis. Even though the crisis has already passed, the world's economy is still suffering from the “pain” it caused. During the crisis, people tried to find what contributed to the nightmare of global financial system, tried to identify what we did wrong to make us deserve the crisis. Then the academics reached to an agreement that it was the financial regulation system we deeply trust and relied on cause all the trouble.Once the government noticed the old financial regulation system is defective, here comes the improvement. Regulation reshaping and regulation reforming is one the significant feature of the nowadays global financial system. Stock market, as one of the most common financing market, is also being reformed. The thesis here of attempt to establish a landscape of the world new stock market regulation system and offer a framework of comparative research to discuss the content of the regulation system of different countries.In order to accomplish a better and more comparable understanding of the stock market regulation system from different countries, we break the regulation system into four components, which is listing and issuing process, delisting process, the disclosure system and legal environment. The listing and issuing process is the precondition of the stock market and it is also the beginning of the stock trading. The delisting process makes the stock market more healthier since it provide the chance for regulator to expel the undesirable company from the issuing stock to public and make it possible for the company that voluntarily exist the market without harming the stock holders. The disclosure system is the fundamental to the supervisory function of a regulation system. All the supervisory approaches are based on the disclosure system. And the most important change in regulation usually takes place in disclosure area. Legal environment guarantees the enforcement of the regulation and grant the power of regulator.As for analyzing the listing and issuing process, our paper use a two-step study procedure. In the first step, our work show one country's listing and issuing with five aspects, which are the issuing disclosure document, the information quality guarantee and examination system, the approval procedure, the involving regulator and the distinguish features of different country. In our study we find that the expect for Hong Kong due to its single stock exchange station, most of the advanced stock market adopt separate listing and issuing examination procedure which means the government regulator is responsible for the issuing qualify examination and the stock exchange is responsible for the listing examination. Our study also find the USA has the most compliant system involving multiple-examination procedure and multiple-participant and its pattern is profoundly influenced Japan.As for delisting process, our work breaks it into four parts: the delisting entity, the delisting regulator, the delisting standard and the delisting procedure. America and Japan adopt quantity-based delisting standard, which requires the issuers meet certain quantity standards of financial state, stock distribution, and other standards. However in UK, German and HK, the delisting standard doesn't contain much quantity standards. Instead, it more relies on principled-based rules. Our work analyzes characters of both the different kind standards and find in find delisting standard is highly corresponding to the listing requirement it chose when it comes to country adopting quantity-based standardAs for disclosure system, our work analyze it from five different aspects: the rules the disclosure requirements relying on, the periodic report requirements, the ad-hoc report requirements, the penalty and finally the media the information exposed on. our study point out that American disclosure system is a product of the conflict of the quality and contents of the information and the burden the issuer carrying on. This is could be help to understand why American government put <JOBS ACT> into effect to exempt EMG from most disclosure burden put on by S.O.X act. Then our work discuss specifically about the change <JOBS ACT> bring into American disclosure system. Our study also use UK and HK to delivery the fact that second-tier market government usually impose more strict disclosure requirement than the main market. In the most part, our study finds that the advanced market disclosure requirement is converging, especially for the items, which should be contained in the report. However, the difference and uniqueness still exist and are high related to legal system, political factors and cultural tradition. In this part, our work distinguish the public regulated market and private regulated market which only exists in Europe, and use AIM market listing disclosure requirement as an example to analyze the different between them.Our work introduces basic security law structure in different country in the first part of legal environment. Then, our work exams the relation between the legal environment and stock volatility. Our work was originated from Chiou(2011)?Cumming(2014), and differs from the previous study in two aspects. First, instead of using Djankov(2003) index to measure the legal environment which was used by Chiou(2011), we use La porta(2006)-based own rectified index to measure the legal environment. Our index is superior to La porta for 2 reasons. We extended the index range to accommodate more specified requirement in the law. We also updated the former index to fit the changed security law. Second, our work conducts a market-level regression to find out the difference the effect of legal environment on main market and second –tier market.Our empirical findings are as followings. The stock return in second-tier markets is riskier those in main market, as measured by both volatility and global beta. Specifically, the stock returns in the public regulated market are less risky. We also find out that disclosure system and judicial efficiency play the most important role in regulating system. In public regulated market, the stock volatility is negative to regulator index, which means public enforcement does work in the regulation system.In the last, we compare Chinese stock market regulation system to the international regulation systems. We find out that auditor system of listing process,ST delaying procedure in the delisting system,incomplete disclosure system and overlapped legal requirement are the major differences between our regulation system and international ones. We analyze that the over-speed regulation reforming, blindly copying other regulation moves and the position the government has put stock market into are reasons that cause the difference. According to the experience we learn from other system,we suggest that in order to enhance our own regulation system,we should improve the knowledge level of common investors,the role of government,the credit of market media and gradually cancel the ST delaying procedure,transform auditor system into register system by markets. |
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