La corporate governance bancaria: annotazioni comparatistiche e nuove prospettive

In some countries, the regulation of bank law is considered a subject of special standardization, in others the general law of companies is modified to accommodate that of banks and create the same conditions of regulatory competition, without however excluding that the company law of banks has a special nature. Of the countries that regulate banks in a special way, to propose a comparison, we have chosen: French regulation and US literature. The reasons for the choice are linked to the structural differences of the corporate regulation and to the consequent interpretative indications that can be obtained. Furthermore, in this way it can help to underline the common content in European countries of banking regulation in terms of governance of Directive 2013/36/EU (CRD).