| Securities market is the outcome of market economy, the weather glass of market economy. Among market economy countries, American securities market and securities legal system are typically significant. Besides, changes of American securities market directly influence securities market of other countries and America's regulating on securities issue and trade legal system are relatively perfect, playing a role of demonstration and reference for the world; Japanese securities market is one of mature markets in the world and there are many lessons to learn in its development process. Securities supervision is the totality of activities as the supervision department supervises and regulates the issue and transaction of securities and the subjects involved in securities marketing, in purpose of maintaining the sequence of securities market and ensuring legal actions. Securities market of America and Japan take the government regulatory model. It is the government who regulates the national securities market by establishing specialized institutions for securities supervision, and issuing related management regulations and laws and putting them into force. Due to such a model, the government, actively involved in the market management, plays a major role in regulating securities market, while the stock exchange and securities commission plays auxiliary role. Though American model and Japanese model share common in main features, there lies certainly differences and divergences in these two models due to the historical background of market development and the degree of the economic development of the two countries as w e l l a s t h e i r r e s p e c t i v e w a y s o f s u p e r v i s i o n . Multiple-leveled supervision department and laws and regulations could be found in Both America and Japan. America is of typical government supervision model. Securities Exchange Act of 1934 prescribes the establishment of Securities and Exchange Commission. Securities and Exchange Commission has broad functions as to institute and adjust the management acts concerned, institute and gives an elaboration on acts and laws for securities market, regulate the activities of issuing and transaction of all kinds of securities, investigate on illegal activities and enforce the measures of both administrative and legislative measures to maintain the market order. As the supreme administrative institution in charge of supervising national securities market, Securities and Exchange Commission has the right of legislation and jurisdiction just to some extent, the function as supervise the issuing and transaction of securities and the activities of investment bank, securities issuer and main shareholders. On the premise of maximum protection for the investors and minimum intervention into the market, information system for the investors should be set up to enable the investors to make the correct choice of investment. Since 1940, American federal government hasinstituted a series of acts and laws to endow Securities and Exchange Commission with more purviews including the right of investigation and sanction. More purviews have been endowed since Market Reform Act of 1990 as the right of exertion in emergency, the right of supervision over big deal and enforcement of acts, which make Securities and Exchange Commission the real ruler of A m e r i c a n s e c u r i t i e s m a r k e t . The supervision system for American Securities market is in shape of pyramid. On the top of the pyramid lie U.S. congress and Securities and Exchange Commission which supervise the market and supervision institutions set up by respective states functioning in its district. In the middle of the pyramid is the self-disciplined institutions as New York Stock Exchange and other Stock Exchanges, NASDAQ, liquidation companies and securities acts formulation committee, all of which would supervise their respective members. Supervision departments of companies mentioned above are the basis of the pyramid, in charge of supervision over the businesses and client complaints and responding to inquiry of supervision institutions. Japan's Ministry of Finance is in charge of making policies for its securities market which hence totally cater to the need of macro regulatory. After the reform, however, the newly-established financial supervision department has taken the role of supervising all aspects of transactions banks, insurance market and securities market involved in. Supervision committees and councils are alsounder its control. The seemingly separation from Ministry of Finance can not prove the fact that financial supervision department of Japan is still the organ of government to make even ends. The prevailing practice of divided operation since Second World War is in favor of government control to prevent 'profit conflict'. Since the opening of interest rate in 1978, divided operation was considered as a hampering the financial development and mixed management becomes prominent. As for the admittance to securities market, both America and Japan take registration system. Especially worth mentioning is the fruitful practice of Japan's control over admittance to its securities market since Second World War. As the development of both economy and society, Japan constantly readjust its admittance policy to ensure the excess profit in the business and put a ceiling on the number of financial institutions to maintain the dominance of existing financial institutions, which, to some extent, help the rapid economic growth of Japan. Both America and Japan have a developed securities market after rounds of reform. The key is how to keep away the risks, especially the risks of supervision over securities market, which China could learn from. As a developing country, China's securities market is established and developed when the transform of whole country from planned economy to market economy. After 10 years of development, China's stock market has made astonishing achievements despite itsimmatureness compared with that of other developed countries. However we cannot just see the bright side and turn deaf ear to those hidden malpractice and imperfection. It has been high lightened as how to ensure the healthy and rapid development of China's securities market along with that of economy. Based on the experiences drawn from the development of American and Japan's securities market, the following suggestions are put forward: Firstly, the establishment of supervision departments should be regulated as well as distribution of responsibility and effective supervision system. Currently China's securities regulatory commission is the regulatory institution in charge, but the institutions of supervising the management is in absence. Without supervision corruption erodes; without subsidiary management, the policy and regulations issued is hard to ensure its force and therefore the healthy development of securities market. Secondly, America and Japan has taken different admittance system in different periods in case of ineffective supervision. China's securities market is at chaos since it's still at its beginning stage which requires the approval system; however, mixed management is inevitable trend as chin's entry into WTO and the development of securities market. Thirdly, related policies should adjust in accordance with both time and current conditions. After China's entry into WTO, divided operation system faced great difficulties and challenges. Mixed management and supervision is the inevitable trend. And how to adjust our policy is also of great...
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