Comparative studies of payment systems between China and Canada, USA, EU: Legal and regulatory issues

This thesis will explore the deficiencies in the legal and regulatory framework of China's large value payment system and recommend solutions for these deficiencies. In order to find appropriate solutions this thesis will survey basic tenets and best practices of other payment systems. Comparison with the experience, theories and practices of Western payment systems is invaluable for assessing the legal and regulatory mechanisms which support China's National Advanced Payment System and High Value Payment System. However, any assessment cannot ignore China's background, including its unique legal and political systems. Chapter 1 analyzes domestic large value payment systems in Canada, the United States and the European Union. Chapter 2 mainly discusses two legislative models for large value payment systems: Uniform Commercial Code. Article 4A (the United States) and the Payment Clearing and Settlement Act (Canada). Chapter 3 analyzes the legal context of Chinese payment systems. Chapter 4 discusses proposals for the legal and regulatory redesign of China's High Value Payment System. This thesis recommends changes to China's payment system through an incorporation of certain aspects of Western payment systems.