近一百年来,全球金融危机的此起彼伏,使人们更多企求借助国家干预强化金融监管,实现金融调控。然而,西方发达国家是在商法高度发达、金融高度市场化的基础上,将国家干预作为商法 In the recent one hundred years, the global financial crisis came one after another, causing more and more people to resort to state intervention to strengthen financial supervision and financial regulation. However, on the basis of a highly developed commercial law and a highly marketized financial market, the developed western countries regard state intervention as a commercial law