它山之石可以攻玉,本文分别选取了行业协会及其立法较为发达且具有一定代表性的德国、日本、美国作为比较研究的对象。对三个国家所代表的三种立法模式现状进行了分析,并在此基础上,对三种的立法框架、法律形式、设立模式、治理结构、筹资模式和营利禁止五个方面的内容进行了比较研究,并从中总结出具有启示意义的先进立法经验,以期对我国行业协会立法有所助益。 It can be jade stone mountains, the paper selected the industry associations and their legislation is more developed and have a certain representation of Germany, Japan, the United States as a comparative study. Based on the analysis of the current situation of the three legislative modes represented by the three countries, and on the basis of the three legislative frameworks, legal forms, establishment models, governance structures, financing models and profit-making prohibitions Comparative research, and summarize the enlightenment significance of advanced legislative experience, with a view to the legislation of our trade association is helpful.