| The Hong Kong securities market develops in a highly open economic and financial environment for long time. Its level of development is far higher than the Chinese mainland securities market. The success of Hong Kong securities market is the outcome of combined action of various factors. Appropriate and effective market regulation played a very important role. Its insider trading regulation has accumulated some experience, formed a set of laws, investigation mechanism and punishment mechanism, meeting the market development stage and social development stage. The Chinese mainland securities market will be in line with the developed securities markets such as Hong Kong. Therefore, using the experience of Hong Kong’s securities market insider trading regulation is of great significance.This paper will be divided into five parts:The first part mainly introduces the main theories of insider trading and part of empirical research, and the significance of the research topic and the main research methods.The second part mainly compares the securities market insider trading regulation category in Chinese mainland and Hong Kong. First of all, compares the scope of securities market insider trading subject in Chinese mainland and Hong Kong, and points out the deficiencies of scope of securities market insider trading subject in Chinese mainland. Secondly, compares the range of securities market inside information in Chinese mainland and Hong Kong, and points out that the range of securities market inside information in Chinese mainland does not match the trend of the market development. Thirdly, compares the scope of securities market insider trading behavior in Chinese mainland and Hong Kong, and points out the defects of securities market insider trading exception exemption category in Chinese mainland.The third part mainly compares the mechanism of securities market insider trading investigation in Chinese mainland and Hong Kong, focusing on the difference of power and procedure of securities regulatory investigation, and points out that the mechanism of securities market insider trading investigation in Chinese mainland don’t match the market development trend.The fourth part mainly compares the mechanism of securities market insider trading punishment in Chinese mainland and Hong Kong, focusing on procedures, standards and penalties, and points out the worthy content for Chinese mainland.The fifth part puts forward some countermeasures to strengthen the mainland securities market insider trading regulation, based on the securities market development stage and the social status quo and trend of the rule of law environment. These countermeasures concern laws and regulations, investigation mechanism and punishment mechanism.The innovation of this article is the policy recommendation that include 14 operable suggestions to improve mainland securities market insider trading regulation. The author carried out On-the-spot investigation about Hong Kong securities market regulation, and studied 96 cases of insider trading and a lot of firsthand material, combine his supervisory experience in the mainland stock market, based on systematic comparative analysis of the regulatory scope of the mainland and Hong Kong stock market insider trading regulation, investigation mechanism and punishment mechanism. |
PDF Full Text Request