中文摘要：

在详细阐述并综合比较美国、欧盟、中国等地第三方支付监管机制的基础上,本文重点探讨了我国构建和完善第三方支付监管机制的相关建议。本文认为,我国目前将第三方支付机构定位为非金融机构的做法在短期内能有效防范风险,但在长期内不利于金融创新;第三方支付机构性质的法律定位与监管体制的错配会逐步降低监管效率;综合运用机构监管和功能监管的组合监管模式更适合于我国;强化信息披露制度、适当降低行业准入门槛、建立灵活的备付金管理制度是健全我国第三方支付监管体制的重点措施。

英文摘要：

On the basis of detailed explanation and comprehensive comparison of the third- party payment regulation mechanism of United States, the European Union and China, this paper mainly discusses some suggestions about the establishment and improvement of the third-party payment regulation mechanism of our country. According to this paper, seeing third-party payment as non-financial institutions can effectively guard against risks in the short run, it will have negative effects on financial creation from the long run, however. Secondly, the mismatch of the legal position of third-party payment institutions and the regulation mechanism will gradually reduce the regulation efficiency. Thirdly, it is much more adaptable for China to combine the supervision pattern of institutional regulation and functional regulation. Finally, strengthening information disclosure system, decreasing the industry admittance threshold and setting up flexible excess reserves management system are the key measures to improve third- party payment supervision system of our country.