中国银行业萌芽于清末，发展于民国，银行监管制度也随中国银行业的发展而不断完善。1912-1935年间，政府对金融业干预有限，属于自由市场型金融制度时期，银行业按市场导向自主发展。本文以华资银行业的翘楚——中国银行为主要考察对象，从市场角度入手，重新考察民国时期的银行监管制度。试图阐明1912-1935年间中国银行业在政府和中央银行监管缺失情况下，如何从自身需要、市场需要和规避风险出发，通过多种措施达到有效监管的效果。 本文运用金融监管理论和制度变迁理论，以历史学的研究方法为主，分三章展开讨论。第一章，简要概括1912-1935年间历届政府监管措施，从监管主体、监管措施、监管法律的实施等几个方面对政府监管措施的有效性进行分析。认为此时期政府对银行业的监管办法不多，效果有限。第二章，中国银行业通过自身监管、行业监管的方式，降低营业风险，实现了“盈利性、安全性、流通性”的统一。中国银行业不断完善内部结构加强制度建设，其中稽核制度、分区制度、人事制度是银行内部自我监管的重要方面；银行公会又通过设立公共准备金、规范会员银行经营行为等方式，有效抑制了银行业的投机行为，维护了银行信用。第三章，市场力量通过金融危机、银行挤兑等方式，迫使银行不断完善信息披露制度。以《银行周报》为代表的金融报刊，及征信所、会计所等社会第三方金融机构也发挥了重要监督作用。文章最后得出结论：1912-1935年间在以市场监管为主的银行监管体系当中，政府监管缺位。在市场力量作用下，银行业以及银行公会、征信所、会计所，作为市场、银行之外的第三方，以其自主、活跃和首创精神，体现出强有力的约束力。

The banking industry in China sprouted in late Qing Dynasty and developed in Republic of China. Banking supervision system also improved with the development of the banking industry in China. The time between 1912 and 1935 is a free-market based financial system period, during which the government intervention in banking business is so limited that China capital banking industry developed on its own based on market. Taking the leading China capital banking industry - Bank of China as the main study object, this paper re-examines the banking supervision system in Republic of China from the perspective of market. The paper attempts to make it clear that starting from its own needs, market needs and risk-avoiding , how did the banking industry in China achieve effective supervision through a variety of measures in the absence of the role of government and central bank from 1912 to 1935.This paper draws on financial supervision theory and institution change theory, mainly deploying the research method of history. The discussion in the paper can be divided into three chapters. The first chapter is a brief summary of successive governments' regulatory measures from 1912 to 1935; this chapter makes an analysis of the effectiveness of governments' supervision measures from the aspects of supervision subjects, supervision measures as well as the implementation of supervision law, coming to a conclusion that the governments' regulatory methods of banks are not many and the effect is limited during this period. In Chapter II, China capital banks reduced business risk and achieved a "profitability, safety, negotiability" unity by using the approach of self-regulation and industry regulation. China capital banking industry continued to improve the internal structure and to strengthen construction of system, among which the audit system, partition system and personnel system are the important aspects of bank self-regulation; banking industry association effectively inhibited speculation in banking industry to maintain bank credit by means of the establishment of a public reserve, standardization of business activities of member banks, etc.,. In Chapter III, market power forced banks to constantly improve the information disclosure system through financial crisis, bank runs, etc. "Bank Weekly", on behalf of the financial press, as well as credit agencies, institute of accounting, etc., as social third-party financial institutions, also played an important supervisory role. The article finally concludes: market-based banking supervision system was in the absence of government regulation. Under the action of market power, banking industry, association of banking industry, credit agencies and institute of accounting, as the third-party outside market and banks, reflected a strong binding effect based on their autonomy, activeness and initiatives.