A Critical Comparative Analysis of the Emerging and Maturing Regulatory Frameworks: Crowdfunding in India, USA, UK

Par Divya Ashta


This research paper undertakes a critical comparative analysis of the emerging regulatory framework relating to Crowdfunding and P2P Lending in India with the corresponding rules and regulations prevailing in the USA and UK in order to ascertain whether the draft regulatory framework in India is capable of extracting experiences and lessons from already enacted and mature regulations. We find that in framing the draft legislation in India, the regulators have obtained valuable guidance from a number of evolved legislations inter alia including USA, UK, France, Canada and Japan. The draft legislation proposed in India is innovative in many ways as the securities and banking regulators have attempted to adapt the various rules and regulations to the existing institutional infrastructure in India. However, in doing so, at times, the legislator forgets that at the early stages of an industry, regulation should be enabling and not limiting.
JEL Codes: K22, D14, G2, L86, M38, O16


  • comparative analysis
  • crowdfunding
  • P2P Lending
  • India
  • USA
  • UK
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