关键词: 参与分配, “个别式”执行体制, “概括式”执行体制, 执行优先主义, 一般破产主义

Abstract: Due to the difference of the execution mechanism， the participation in distribution system shows different operation patterns between China and civil law countries. Since the individual execution system blocks the access of the enforcement agency to the debtor's property information， the participation in distribution system in the civil law countries only deals with the distribution of the debtor's specific property， but not the bankruptcy matters. The absence of the unincorporated bankruptcy system makes the participation in distribution system in China undertake the quasi-bankruptcy function. However， the execution nature of the participation in distribution system determines its consistency with the bankruptcy system. In addition， the existence of the participation in distribution system limits the application of the bankruptcy system. On the premise of maintaining the generalized execution system， it is still impossible to overcome the fundamental defects of the participation in distribution system simply by internal modification. Therefore， it may be advisable to abandon the participation in distribution system but implement the execution prioritarianism and general bankruptcy doctrine.

Key words: participation in distribution, individual execution system, generalized execution system, execution prioritarianism, general bankruptcy doctrine