This article presents a summary of the regulatory systems currently in place in the world's major markets. This summary focuses primarily on the disclosure rules that must be followed by a company undertaking an equity offering in each country. Certain significant accounting standards also are discussed. After comparing the different disclosure frameworks, the article addresses efforts that have been made to regulate or standardize the world's markets on a more international level. Finally, the article discusses where we should go next in the quest to create greater harmony in a truly global marketplace.
Marc I. Steinberg & Lee E. Michaels,
Disclosure in Global Securities Offerings: Analysis of Jurisdictional Approaches, Commonality and Reciprocity,
Mich. J. Int'l L.
Available at: http://repository.law.umich.edu/mjil/vol20/iss2/17