中国与美国的托管结算系统存在许多相似性,两国都建立了中央托管机构,都实行分级托管,并采用“券款对付”。但中国的托管结算系统在很多方面还无法达到美国的水平,这主要体现在中央托管结算机构的服务等方面。针对这些不足,主要的改善措施有:实现托管体系的统一性以及完善中央托管机构的职能等。 China and the United States have many similarities with the trusteeship and settlement system in the United States. Both countries have established central trusteeship bodies and have implemented trusteeship at different levels and adopted “vouchers and payments”. However, China’s managed settlement system can not reach the level of the United States in many aspects. This is mainly reflected in the service of the Central Depository and Clearing Office. In response to these deficiencies, the major improvements include: the realization of the unity of the custody system and the improvement of the functions of the central custodian.