Aug.23.2004

Japanese Bankers Association

JBA Submits Opinion Paper on Administrative Legislation Procedures

JBA finalized an opinion paper concerning administrative legislation procedures at the Planning Committee held via written participation on August 19, and submitted it to the Office of Administrative Procedure of the Administrative Management Bureau at the Ministry of Internal Affairs and Communications (MIC) on August 23. This was done in response to the soliciting of opinions for the Study Group of Administrative Procedure Law (established in MIC) to take into consideration.JBA commented on the main points of discussion that MIC had presented, namely "the scope of legislation to solicit comments on," "drafts on which comments are solicited," "period for inviting comments and means for submitting comments" and "announcement of results."Specifically, JBA requested clarification of the criteria for the scope of legislation to solicit comments on, publishing of materials to help deliberate on drafts for which comments are being solicited as much as possible, securing of a sufficient period for soliciting comments and plain disclosure of reasons for comments not being adopted.