한·미·EU의 보험·금융투자지주회사에 대한 비교법적 연구

Since 2007, most of countries including Korea in the world have had tremendous difficulty experiencing financial crisis originated from the United States. Such a financial crisis in the United States resulted from the ineffectiveness of non-bank financial groups like non-bank holding companies. Because of that, many non-bank financial companies went bankruptcy and there exist some rooms. Only if such a market vacuum is superseded by Korean non-bank financial companies, it must be an opportunity for Korea. For this, the article exams the legal systems of Korean, the United States and European Union (hereinafter EU) on non-bank holding companies such as insurance holding company and financial investment holding company and learns lessons from them as follows: (1)difference of non-bank holding companies and between bank holding company and non-bank holding companies, (2) whether or not individual regulations for non-bank financial holding companies exist, (3) supervisory regulator over non-bank holding companies, (4) credits within the entire non-bank holding company system including holding company and its subsidiaries, (5) internal control system and compliance officer, and (6)concurrent office. The author concludes that the Korean non-bank financial holding company follows the global trend. However, Korea needs to prepare for alternative mechanism to prevent risk contagion from non-financial subsidiaries to other financial subsidiaries and their holding company. In this sense, the author also suggests that Korea continues to examine a reasonable measure to improve non-bank financial holding company system under the Korean Financial Holding Company Act.