Danno e responsabilità delle autorità di vigilanza e regolazione. I modelli statunitense e francese

This article analyses, from a comparative perspective, the theoretical-normative models of supervisory and regulatory authorities’ liability for damages in the U.S. and French systems.\r\nIt seeks to reveal the broad variety (in types of liability) present in such models, the correlation between liability and the evolution of the role and powers of su- pervisors and regulators, the impact the evolution of legal systems (in particular in relation to the French system) has both on the theoretical framework and the regime on damage liability for damages and the political-legal tensions con- cealed behind its evolution.\r\nIt is precisely due to the marked diversity in the approach taken by the two countries that it is possible to deduce certain information that is very useful for the wider debate currently taking place on these themes and also to understand the role played by the various stakeholders – legislator and courts in the first in- stance – in governing the new issues arising in liability cases.