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中国股市的巨幅振荡引发了对于我国证券发行、交易、登记、服务、监管等问题的重新思考。我国正是在这一背景之下引入了熔断机制。我国熔断机制于2016年1月1日起实施,仅触发了四次就于2016年1月8日起暂停实施。针对熔断机制学界与业界均褒贬不一。甚至有学者认为我国已有涨跌停板制度,熔断机制并无存在的必要性。本文通过考察美国熔断机制的演变,对比熔断机制的中美差异,剖析了在我国熔断机制失败的原因主要在于投机性的市场和以散户为主的市场结构而不在于熔断机制的本身。本文认为熔断机制只要运用得当就可以在我国继续适用,并提出相关熔断机制的完善建议。
The huge oscillation in China’s stock market has triggered a rethinking of China’s securities issuance, trading, registration, service and supervision. It is against this background that our country has introduced a fuse mechanism. The fuse-breaking mechanism of our country came into force on January 1, 2016 and was suspended for implementation on January 8, 2016 only for the fourth time. Fusing mechanisms for the academic and industry are mixed. Some scholars even think that our country has a price limit system, fuse mechanism does not exist the necessity. By examining the evolution of the fuse mechanism in the United States and comparing the differences between the fuse mechanism in China and in the United States, this paper analyzes the reasons for the failure of the fuse mechanism in our country mainly due to the speculative market and the retail-dominated market structure rather than the fuse mechanism itself. In this paper, the fuse mechanism as long as the proper use of it can continue to apply in our country, and put forward the relevant proposals improve the fuse mechanism.