Abstract: CSRC shifted the regulatory path in the Yingyi case of Shanghai because of the policy background of “zero tolerance”, which reveals the practical requirements against the poor effectiveness of the existing behavior regulation and the lack of relief in civil compensation litigation, reflecting the deterrent regulatory strategy of “command-control”. The breakthrough in identifying the nature of behavior in this path shift has already violated the rules and values of information disclosure and share transfer restrictions, highlighting the inherent limitations of the regulatory model based on deterrence strategy, such as the randomness of law enforcement, the tendency to excessive punishment, and the presupposition of antagonistic relationships. The responsive regulation theory breaks away from the single idea of “strengthening deterrence with punishment”, and is committed to building cooperative relationships, which can improve the regulatory efficiency and serve as a basis for China’s securities regulatory reform. However, in the process of its localization, it is necessary to properly handle the incompatibility between it and the local resources of China’s securities regulation, so as to avoid oriented regulatory capture and substantive regulatory relaxation. To play the positive role of the responsive regulation and improve the scientificity and effectiveness of China’s securities regulation, it is necessary to base on the actual needs of China’s capital market, promote the subjective consciousness and ability building of the self-disciplined regulators, optimize the cooperative administrative regulation tools, and ensure the deterrent strength of securities law enforcement.

Key words: shareholding commitment, path switch, securities regulation, deterrent regulation, responsive regulation