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Liburkina L. M.

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The Institutional Models of Financial Consumer Protection: International Experience and National Practice
Murina H. V.

Murina, Hanna V. (2026) “The Institutional Models of Financial Consumer Protection: International Experience and National Practice.” Business Inform 1:464–472.
https://doi.org/10.32983/2222-4459-2026-1-464-472

Section: Finance, Money Circulation and Credit

Article is written in Ukrainian
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UDC 366.336

Abstract:
This article proposes a typology of institutional models for delivering the regulatory mandate of financial consumer protection. Financial consumer protection, alongside general consumer protection, has become an integral part of the governmental role in achieving improved societal outcomes. In line with commitments under United Nations General Assembly resolutions, national governments have adopted various institutional models to perform this role. As no single universal solution exists, this creates a need to systematize international experience, synthesize the strengths and weaknesses of existing models, and identify the key factors shaping the choice of institutional model. The study identifies five main types of such models, including two traditional models – the sectoral model and the consolidated consumer protection model – as well as three models to which national regulators are converging: the North American model, the objectives-based (twin peaks) model, and the Nordic model. For each model, the article outlines key characteristics, provides country examples and implementation features, and synthesizes their strengths and weaknesses relevant for assessing institutional options under specific national conditions. Political-economy and other contextual conditions shaping the choice of institutional models are analyzed separately. The main stakeholders involved in the choice of an institutional model for financial consumer protection are identified, their motivations and potential conflicts of interest are examined, and the reform of financial market regulation in Ukraine is discussed in the context of selecting an institutional model for financial consumer protection. The aim of the study is to systematize international experience in implementing institutional models for delivering the financial consumer protection mandate. The article analyses academic literature on institutional models of financial market regulation, as well as regulatory documents and practices of national authorities. The study employs methods of theoretical generalization and classification to construct the typology of institutional models, and methods of formalization, analysis and synthesis to identify the strengths and weaknesses of each model type.

Keywords: regulation, financial markets, financial services, institutional models, risks.

Tabl.: 1. Bibl.: 13.

Murina Hanna V. – Applicant, Department of Banking and Insurance, Kyiv National Economic University named after Vadym Hetman (54/1 Beresteiskyi Ave., Kyiv, 03057, Ukraine)
Email: [email protected]

List of references in article

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