Convergence in Corporate Governance--Possible, But Not Desirable

THE prospects for international convergence in corporate governance systems have become a hot topic in legal academia. For some time scholars have depicted American corporations and capital markets as optimal adaptations for governing large business enterprises. 1 More recently, American scholars have become more aware that other countries do things rather differently. While large American corporations have many dispersed shareholders and turn to public stock and bond markets for financing, large Japanese and German corporations have more concentrated shareholders and close financial relations with banks