Research On The Comparison Of Sino-US Securities Disclosure System

2006 witnessed the historical change of China's security market. In one year, the Comprehensive Index of Shanghai Stock Exchange skyrocketed from the 1161 points in the beginning of 2006 to 2675 points in the year-end , which represents a drastic rising of 132% ranking first around the world in 2006. Under the circumstance of unprecedented Bull Market, the market value of China A stock market realized the unparalleled increase from 3101.7 billion RMB in 2005 to 8799.2 billion RMB in 2006, which is a growth of 183.69%. At present, China's stock market has become an indispensable part of the world securities market, and nobody can afford to ignore its huge power. With the continuous uprising of china's stock market, the activities of violating securities regulations are still in extensive existence. In 2006, China Securities Regulatory Commission(CSRS) published 38 copies of administrative punishment statements, and there are 22 copies related to the violation of disclosure regulations. So it is not hard to see that the current situation of information disclosure in our country's stock market is far to be satisfactory.The disclosure system of securities information is defined as the whole series of practice custom and action rules obeyed by the relative parties in the securities market (mainly the listed corporation) to publicized the information related to the securities in line with the laws and regulations established by the securities management organization or securities exchange during the securities' offering, listing and trading. The system of information disclosure is key to the legal institution of the modern securities market and the important prerequisite to guarantee the justice, fairness and transparency of the securities market, and it's also the most effective measure of safeguarding the interests of investors. The purpose of this dissertation is to find out the imperfect aspect of our securities disclosure system and provide some useful suggestions to improve our disclosure system on the basis of comparing the two different disclosure systems between China and the United States.The object of the comparison in this dissertation is the information disclosure system of securities market between China and US. In the first place, the article will introduce the origin and the developing history of disclosure system in detail, and at the same time analyze the theoretical foundation and cause of disclosure system. The second part of the dissertation will focus on the similarities and differences of the disclosure systems between the two countries and find out the inappropriate facet of our country's disclosure system. In the third part of the dissertation, the author will lay the emphasis on comparing the civil liability of violating the disclosure system. Based on the comparison of the various aspects of the civil liability resulted from the misrepresentation in disclosing accounting information, the author will reveal the deficiencies existing in our country's civil liability system of misrepresentation. On the foundation of the comparison and analysis summarized from the former parts of the dissertation, the last chapter will point out the current problems of our disclosure system and lodge some unique proposals to improve our country's disclosure system, especially the civil liability institution of disclosure system, hoping of making due contributions to reforming our information disclosure system.