Comparative Study On Financial Trust Business Law

Trust is a mechanism under which trustee manage property for trustor' s interest transferred from trustor. Derived from Anglo-American Equity, Trust has a history of more than 500 years. It has been widely applied in modern financial system as a mature property management scheme.Trust in China can be traced back to the twenties, 20th century. However, it almost disappeared in China for many reasons until China International Trust Investment Company (CITIC) was founded in 1979. After that many trust companies emerged in a short time. In contrast to the rapid development, China has only one regulation for trust businessæ¡°nterim Regulation for Management of Financial Trust Investment Organizations. Simple in content, this Regulation even distorted some fundamental conceptions on Trust.Many countries in the world refer the Trust business model of UK, USA and Japan. It will be of great benefit to China to make a comparative study on these countries' legal environment of trust business. This is also my motive to write this paper.Through one year' s hard work, I concluded the general rule and difference of the UK, USA and Japan legal system of Trust business. I hope this paper could contribute to the modernization of China Trust business.