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The article presents some questions on bank systems in such high developed countries like Germany or the United States of America. The following problems are described:1. organization and main functions of a bank system2. management of a bank risk3. evolution of financial innovations as security techniques4. American and German bank systems' profiles The author has choosen the subjects in order to present the following message: some Polish legal regulations on financial sector functioning are still strongly connected with the old, central and bureaucratic system and even despite the new Act on Polish National Bank and another one on Bank Law it is difficult to develop our financial system in a proper way. It seems to be clear that Polish bank law must be changed. But the question is: whetherthe present law can be modified or, maybe, it is necessary to look for a completly new one. The author suggest that it could be based on one of European countries bank law. French, German or English models of bank system could be adjusted to Polish conditions. On the other hand, the Polish bank law of the interwar period could be also modified and brought closer to the present time. The author studies the experiences and directions of evolution that have been existing so far and he tries to find the answer on the question:: which model of a bank system would be the best for Poland. The bank and economic literature describe the following three basic types of bank systems existing in the world:1. English and American model2. German and Japanese one3. French one that draws from the both mentioned above Knowing the advantages and disadvantages of all of them, it seems that adoption of the German model would be the best solution for our country. It is becouse of tradition (in the iterwar period our bank system was modeled on a German one), direct neighbourhood and the fact that Germany will be our greatest economic partner in the near future. However, we can observe, that European bank systems areovercome by American models determining the standards of contemporary banking in the whole world. So, Polish bank sector must be sensitive to any institutional innovations of American banks. It is also clear that: “The chance for introducing the German model of bank system in Poland is hardly possible without the new, well-trained staff. If we do not choose the target financial system knowingly, it will be automatically pushed to the French model” (J. K. Solarz, Searching for a new model of Polish bank system, Warsaw, September 1994).
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