A Comparative Study On The Legal Regulation Of Crowdfunding

As a new financing mode rising in recent years,crowdfunding generally refers to the crowd to raise small amounts of money through the Internet for the practice of a project or corporate finance,since the international community’s awareness is not entirely consistent.Legal regulation of crowdfunding mainly appeared in American and European countries and specific provisions uneven,usually around the sponsor,crowdfunding platform and investors to expand.As the main force of global crowdfunding markets development,the legal regulation system of China is still in a non-threshold,no standards,no supervision of the "three noes" state,easily lead to systemic financial risks,since crowdfunding has set off a surging wave in the financial markets with its high efficiency,low-cost advantage.Through comparative study theory and practice of various countries to crowdfunding of legal regulation,provide regulatory proposals for the introduction of the current "Securities Act " modifications and related management approaches to improve our legal system.Article is divided into three parts for crowdfunding during the comparative study of legal regulation:The first part of the comparative study of legal regulation of sponsors,comparative analysis of specific provisions of each country from two levels,access and information disclosure obligations,combined with the "Securities Act" to modify the stock issuance registration system established trend,to provide localization advice for the definition of sponsors access in our country.The second part of the comparative study of legal regulation of crowdfunding platform,from access,information disclosure and due diligence obligations,dispute resolution mechanisms combine with crowdfunding models to comparative analysis of specific provisions of each country,to provide recommendations for our platforms registration process and related obligations.The third part is the comparative study of legal regulation of investors,comparative analysis of country specific regulations from the perspective of investor protection and access conditions,combined with the domestic equity crowdfunding tradition of " Leading Investor +Following Investor" model as well as emerging "forward pricing" model,and make recommendations for qualified investors limited after comprehensive comparison of the pros and cons.