Abstract
The paper analyzes the current status of the US and UK’s P2P lending regulation and compares China’s regulatory system with the US and UK’s to extract experiences and lessons from relatively mature regulation. For the US, it does not make any new laws but relies on current existing laws and regulations to supervise P2P lending industry. US’s strong functional regulatory pattern makes it become the strictest in regulating P2P lending among three countries, emphasizing compulsory registration system and constant information disclosure management. Strict regulation makes the P2P lending market more orderly but also restricts the industry’s innovation. For the UK, it does not count on existing laws, but reassesses P2P lending industry and proposes new legal instrument to regulate this novel industry. Appropriate laws can regulate related businesses effectively and also leave enough space for industry’s innovation. Another bright spot of UK’s P2P lending regulation is the strong self-discipline from the industry association, making a great contribution to standardize P2P lending industry, promote benign competition, and protect consumers.
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