美欧征信的制度框架与我国个人征信制度的选择

征信制度作为金融部门发展的基本要素之一，世界上几乎所有的发达国家和绝大部分发展中国家都建立了征信制度。运用新制度经济学的分析框架，从制度的主体和客体、制度的载体和相应的规制3个方面比较了美国和欧洲国家不同征信模式，并结合我国征信实践，提出了我国个人征信制度应选择公私并存，并最终市场化的征信制度。

Credit Reporting System Framework in U.S.and Europe and Choice of Personal Credit Information System in China

As the basic element of development in financial department, credit reporting system has been established in almost all developed countries and the majority of developing countries. This paper, using analytical framework of New Institutional Economics, compares the different credit reporting sys- tems between USA and European countries from the following three aspects： institutional subjects and objects,institutional carriers and corresponding regulations. In combination with China＇s credit reporting practice,this paper points out that China＇s personal credit reporting system should select ultimate mar- ketized credit reporting system in which the public and private credit reporting system co-exist .