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本文从质量和数量两个维度考察中国企业年金市场进入规制。质量规制目标明确,最低资质标准能够保证企业年金基金管理机构的底线质量,但受评审专家与金融机构之间信息不对称干扰,资格认定机制无法保证经营牌照发放给真正优秀的金融机构。资格认定机制也是数量规制措施,监管当局缺乏对企业年金市场合理市场结构的明确判断,政策的摇摆导致早期企业年金市场恶性价格竞争,未来垄断合谋的可能性增强。
This article examines the access regulation of China’s enterprise annuity market from the two dimensions of quality and quantity. The objective of quality regulation is clear and the minimum qualification can guarantee the bottom line quality of the enterprise annuity fund management institutions. However, due to the asymmetric information between the experts and financial institutions, the qualification mechanism can not guarantee the issuance of operating licenses to truly outstanding financial institutions. The qualification mechanism is also a quantity control measure. The regulatory authority lacks a clear judgment on the rational market structure of the enterprise annuity market. The policy swing has led to the vicious price competition in the early enterprise annuity market and the possibility of collusion in the future will be enhanced.