"The paper compares the EU and US securities regulations, and specifically MiFID with the corresponding US regulations. It primarily focuses on the regulatory and supervisory framework, trading venues, and the provision of investment services. The paper argues that the architecture and some of the rules regarding securities markets are different in the two regions, but the objectives and some of the outcomes are similar. It looks at the regulatory frameworks, the scope and objectives of securities regulations, the rules implementing the different objectives, and draws some crisis-related lessons. The primary audience of this study is professionals, government officials and scholars working in the field of securities regulations."
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