OTO No.(584)

Provisional Translation

OTO No.	671	Classification	MOJ-1
Date of Acceptance	November 1, 2004	Ministry/Agency Receiving Complaint	Cabinet Office
Responsible Ministries	Ministry of Justice	Related Laws	Immigration Control and Refugee Recoginition Law
Complainant	Foreign business manager	Exporting Countries	Pakistan
Subject	Clarification of criteria for the status of residence of foreign business managers
Description of Complaint	1.Background (1) Origin of the issue The complainant arrived in Japan in November 1993 and has resided in Japan since then. At first, he worked with the status of residence "Engineer," but he filed an application for change of the status of residence to "Investor/Business Manager" on the occasion of the establishment of a private limited company in 1997. This application was accepted, and he had had the said status of residence since then up to May 2003. However, when the complainant applied for the renewal of visa with the Tokyo Immigration Bureau in May 2003, the bureau did not grant him the status of residence "Investor/Business Manager" despite no significant change in the financial conditions. Subsequently, the complainant was granted the status of residence "Temporary Visitor" from May 2003 and the status of residence "Designated Activities," which is for those who prepare for departure, from September 2004. (2) No notification of reasons for the result of examination for the status of residence When the complainant asked the responsible officer of the Tokyo Immigration Bureau about reasons for refusal in association with the refusal notified in July 2004, the responsible officer stated "slumping business and deficits" as reasons. However, the complainant thought these are not sufficient reasons for refusal and thus asked for the reasons again. Then, the Tokyo Immigration Bureau cited "slumping business" and the fact that "the office is not leased in the name of the principal" as reasons. The complainant visited the Tokyo Immigration Bureau a third time to confirm reasons, and he was then notified of the real reason for the first time: "slumping business was not a reason but the reason was that the office is not leased in the name of the principal." (3) Unclear examination criteria for the status of residence According to the responsible officer of the Tokyo Immigration Bureau, in examining the fulfillment of the requirement "securing a facility used as a business establishment for running the relevant business in Japan," which is one of the examination criteria for the status of residence "Investor/Business Manager" prescribed by the "Ministerial Ordinance to Establish Criteria Mentioned in Article 7(1)(ii) of the Immigration Control and Refugee Recognition Law" (hereinafter referred to as the "Ministry of Justice Ordinance"), the securing of such a facility is determined based on the name of a lease contract for the office irrespective of actual business activities. However, the responsible officer of Tokyo Immigration Bureau did not make public the criteria for relevant determination for the reason that they are "common sense and natural." The complainant, i.e. the applicant, could not know the criteria when filing the application. (4) Arbitrariness of examination for the status of residence At the time of refusal notified in October 2003, the responsible officer of the Tokyo Immigration Bureau explained that the application was refused because "employment of two employees cannot be confirmed," and also instructed the complainant to fulfill the said condition. Therefore, the complainant fulfilled the condition by dismissing a then director, who was also investor, and employing him as an employee, and filed the application again. Then, the application was refused on the ground that the lease contract for the office was in the name of the said investor who had been a director. Incidentally, it has become clear, subsequently, that there is no need to fulfill the said condition (employing two or more employees) if the investment of \5 million or more is confirmed (investment made by the complainant in the relevant company amounted to \9.25 million). 2. Problems The status of residence "Investor/Business Manager" serves as a basis for foreign nationals to conduct corporate management activities in Japan. The reliable acquisition of that status is essential for stable corporate management. Thus, applicants are by necessity prepared to develop the qualifications to pass examination. However, since examination criteria themselves are not clear, applicants cannot develop the qualifications even if they try to do so, and they, therefore, cannot avoid the risk that their applications will be refused. This unpredictability of the situation where a business manager cannot stay in Japan due to refusal of an application for the status of residence "Investor/Business Manager" is a factor that impairs stability in management. Incidentally, even if examination criteria are not clear, if proper reasons for the result of examination of an application are clearly communicated to the applicant, required corrections will become clear at this stage. However, such has not been conducted (in this case, the "reason" presented changed, and untruthful explanation was given at the beginning). In this manner, examination criteria and reasons for refusal are not made clear under the current immigration control. This has been causing the situation where applicants do not have the opportunity to understand an application form in line with laws and ordinances, and thereby defects arise in the contents of applications filed by applicants. It has also been causing the situation where Immigration Bureaus arbitrarily decide on whether applications pass examination. Such a situation poses a major obstacle to foreign nationals' starting up business and conducting activities in Japan. The applicant's company has achieved a large number of satisfactory results, including winning an award from a public organization, through corporate activities in Japan in the past seven years. Therefore, the company has never been given discriminatory treatment by private companies, including lending financial institutions, for the reason that the manager is a foreign national. However, customer companies, etc. have come to doubt the stability of the company, which is managed by a foreign national, due to the refusal of an application for the status of residence "Investor/Business/Manager" this time. While the Japanese government is indicating the policy of actively accepting investment in Japan as well as foreign engineers and entrepreneurs, the above-mentioned situation certainly brings about results not only against our company but also against foreign nationals who intend to start up business in Japan, and it may become a barrier to investment in Japan, etc. in the future. 3. Request for alleviation, etc. In light of the above-mentioned problems, the complainant requests the alleviation of problems in the following way. (1) Clarification of examination criteria The ministry shall clearly indicate acceptable matters and unacceptable matters so that applicants can understand an application form in line with laws and ordinances. The ministry shall make sure that examination is conducted not based on "common sense" as mentioned by immigration inspectors but based on examination criteria in the statutory form. (2) Publication of examination criteria The ministry shall publish examination criteria established as above and implement measures to ensure that all applicants know the criteria. Incidentally, there are two types of the period of stay for the status of residence "Investor/Business Manager," one year and three years. However, conditions for the determination of the period are not clear, and they should also be made clear. (3) Clear indication of examination results and reasons thereof If an application is refused as a result of examination, reasons thereof should be clearly explained in light of examination criteria in a "notice" so that the applicant can understand. (4) Realization of immigration control reflecting the national policy In consideration of the national policy of actively accepting investment in Japan as well as foreign engineers and entrepreneurs, influence on relevant company's responsibility for shareholders, customers, financial institutions, etc. shall be sufficiently taken into account in the examination of the granting of the status of residence "Investor/Business Manager." Incidentally, although it has taken a lot of time to examine applications filed from last year onwards, if the period of stay expires during the period between when an applicant applies for renewal of visa and when the result of examination is made, the applicant will substantially have no visa. That will obstruct business trips to overseas and conclusion of new contracts with financial institutions. Therefore, we request that the ministry consider the speeding up of examination. (5) Regarding examination criteria for the status of residence "Investor/Business Manager" The Tokyo Immigration Bureau informed the complainant of (i) "slumping business and deficits" and (ii) the fact that "the office is not leased in the name of the principal" as reasons for the refusal of application for the status of residence "Investor/Business Manager." However, the Ministry of Justice Ordinance, etc. does not stipulate such a requirement. We would thus ask the Immigration Bureau to clarify reasons for citing them as reasons for refusal. (Opinion No. 2 on December 2, 2004) 1. Matters considered to be behind the complaint From the contents of the Ministry of Justice's reply, we consider that the following problems in the current Immigration Control and Refugee Recognition Law, Ministry of Justice Ordinance and immigration control administration are at the root of ambiguous examination criteria, arbitrary examination by immigration authorities and other causes of the complaint. Problem 1) The current Immigration Control and Refugee Recognition Law, Ministry of Justice Ordinance and immigration control administration are not based on the premise that start-up and continued business operation are achievable without large-scale capital and facility in recent years. Therefore, for companies that have neither large-scale capital nor facility, Immigration Bureaus sometimes conduct arbitrary examination based on the hidden examination criteria called "common sense." Moreover, such examination is not based on the understanding of the actual condition, and is preoccupied with formal examination. Problem 2) The current Immigration Control and Refugee Recognition Law, Ministry of Justice Ordinance and immigration control administration are not based on the premise that foreign nationals start up technology venture companies. Therefore, investment after start-up and deficit thereby, which are common among technology ventures, are automatically viewed in a negative light, and the financial condition of companies is uniformly determined only based on deficit. We thus request that the ministry take into consideration changes in the forms of companies and in the economic situation in recent years and make drastic reviews and improvements to realize immigration control administration, which conforms to the policy of actively accepting foreign engineers and entrepreneurs announced by the government and the business world. 2. Counterargument against the Ministry of Justice's reply (particulars) (1) Clarification of examination criteria Especially questioned in this complaint is the existence of hidden examination criteria that are sometimes called "common sense" by Immigration Bureaus, which are used by Immigration Bureaus as criteria in the actual examination of the status of residence, though they have been neither specifically provided in the Immigration Control and Refugee Recognition Law nor clearly established in the Ministry of Justice Ordinance and their specific handling has not been placed on the Ministry of Justice's website. All examination criteria that influence the result of examination of applications should be put in the statutory form so that applicants can recognize them at the time of filing applications. (2) Publication of examination criteria Given the current situation where immigration control administration does not incorporate changes in the forms of companies and in the economic situation due to the problems mentioned in 1 above, the specific way of handling the status of residence has not been sufficiently clarified yet. All examination criteria that influence the result of examination of applications should be first clarified, and then, steps for publication should be taken to ensure that all applicants could recognize the criteria before filing applications. In addition, though the ministry cited "failing financial condition of the business establishment like in this case, specifically, annual sales of \17 million and a loss of \47 million," as a reason for determining the period of stay and thereby intended to give the strong impression of slumping business, this fact does not serve as the reason because quoted figures are those after the applicant lost the status of residence "Investor/Business Manager." (3) Clear indication of examination results and reasons thereof Texts that give explanation about refusal in notices are ambiguously written by a few lines, such as "not being recognized that there are reasonable grounds" and "not being recognized as being based on a special unavoidable circumstance." Applicant cannot understand the exact reasons for refusal from such texts. Under the present situation where hidden examination criteria exist and arbitrary examination is conducted, applicants are further bereft of the opportunity to understand reasons for refusal. Although the clarification of examination criteria is first required, Immigration Bureaus should also describe, in notices, nonconforming points if applications are refused due to nonconformity to the requirements. The scope of description of such "points" should be broad enough to enable applicants to make improvements and re-file applications in conformity to the requirements after reading the description without receiving other explanation. (4) Realization of immigration control reflecting the national policy Since venture companies just after start-up are "new businesses," the period of stay is often determined as one year. Such companies do not have "scale," let alone "past achievements," in many cases, so they are often deemed to be highly "likely to cause such problems as overstaying." For this reason, despite the short period of stay permitted, a lot of time is required for examination for the visas of business managers of venture companies just after start-up. This imposes a heavy burden on venture companies with relatively small corporate vitality just after start-up. Though measures to expedite and simplify examination for the status of residence have been taken, these measures bring into view only large companies and formal organizations. It took nine month from my filing the previous application to receiving the examination result. On the top of the lack of comprehension of the actual condition, it took far too long. During such a period, my company cannot conclude new contracts with financial institutions because I, the representative of the company, do not have a working visa. Moreover, I cannot go abroad, and business activities are thus significantly hindered. Ventures just after start-up have difficulty in gaining trust from corporate shareholders, customers, financial institutions, etc. compared to stable large companies. The ministry must eliminate the possibility that applications for the status of residence of business managers will be unreasonably refused due to unclear examination criteria and arbitrary examination by Immigration Bureaus. (5) Regarding examination criteria for the status of residence "Investor/Business Manager" The examination criteria for the status of residence "Investor/Business Manager" are stipulated, in 1 of the Ministry of Justice Ordinance "Ministerial Ordinance to Establish Criteria Mentioned in Article 7(1)(ii) of the Immigration Control and Refugee Recognition Law," as falling under all of the following. a) The facility used as a business establishment for running the relevant business is secured in Japan. b) Relevant business is of the scale run by the engagement of two or more full-time employees residing in Japan (excluding those who reside in Japan with the status of residence in the upper column of Annexed Table I of the law) in addition to one who engages in the management or administration of the business. 1) In terms of the scale mentioned in b), there is an established guideline: the case where the amount of investment is \5 million or more and sustained investment of such amount is confirmed. The complainant has invested \9.25 million out of his own company's capital of \10 million, and thus, he fulfills the provision of the above-mentioned guideline. The responsible ministry stated: Since recognition of the status of residence "Investor/Business Manager" is for foreign nationals who start business management in Japan, invest in business in Japan, or manage and administer business on behalf of a foreign national who did the above, these activities have to be continuously conducted. Therefore, the continuity of relevant business is an important factor in asserting that foreign nationals fall under the said status of residence. However, there are no provisions to that effect, and the responsible ministry has arbitrarily conducted examination for the status of residence based on that nonexistent provision. In addition, the ministry made the following determination based on such arbitrary determination criteria: Continued deficit in the business managed and administered is a factor that raises questions in considering the continuity of the business. This determination is inappropriate as mentioned below. When I applied for the status of residence before, the Immigration Bureau defined my company as suffering from slumping business only because it "had deficit," without conducting specific survey or analysis of the financial condition thereof. However, there are various kinds of companies and a variety of styles of investing people, things and money, and stable sales and scale are not necessarily required. In particular, technology ventures have the higher possibility of creating added value through business, and they often make large investment in anticipation of future great profits. Therefore, deficit just after start-up is not rare. The continuity of such business cannot be determined simply based on deficit, and it should be analyzed from multifaceted viewpoints, including technical capabilities, intellectual property, ability to create added value and market value, and be finally confirmed based on the intentions of shareholders and business managers. Immigration Bureaus should not be allowed to put an end to companies by arbitrary examination without going through such analysis and confirmation. If Immigration Bureaus have the possibility to do so, ventures just after start-up will not be able to conduct business with the confidence of shareholders, customers, financial institutions, etc. (However, the fact I confirmed when I received explanations on reasons for refusal directly from the responsible officer of the Tokyo Immigration Bureau was that this item of slumping business was not the major reason for refusal and that the reason for the refusal was the fact that the office was leased neither in the name of the company nor in the name of its representative.) 2) Regarding the criterion established by the Ministry of Justice Ordinance, "a business establishment exists in Japan," the Ministry of Justice stated in its reply that "In the case where a lease contract was concluded neither in the name of a company nor in the name of its representative, the Immigration Bureau cannot recognize that the applicant conforms to the requirement of securing of a business establishment unless an especially reasonable ground is indicated, though the Immigration Bureau may, in some cases, recognize no problem in terms of the securing of a business establishment." However, applicants have no means of knowing the existence of such examination criterion at the time of filing applications. In addition, the name of a lease contract for the current office actually has not posed any obstacles to the operation of my company's business activities. Generally, it is not rare that a lease contract for a corporate office is concluded neither in the name of the company nor in the name of its representative. Moreover, in the case of our company, the lease contract was concluded in the name of an investor in our company, and the party to the contract is thus not irrelevant to the company's profits. It is unfair that the Immigration Bureaus recognize that a business establishment is not secured "if a lease contract was concluded neither in the name of a company nor in the name of its representative."
Details of Measures	1. The Ministry replied as follows: (1) Clarification of examination criteria The Immigration Control and Refugee Recognition Law clearly specifies policy for the acceptance of foreign nationals through establishment of the statuses of residence in its Annexed Tables, and specifically stipulates activities in which foreign nationals residing in Japan with the status of residence may engage in Japan, in order to stabilize the legal status of foreign residents residing in Japan. Moreover, criteria based on academic background, the amount of remuneration and other factors were established in terms of the scope of foreign nationals subject to landing permission under certain statuses of residence, from the viewpoint of impact of foreign nationals' entering and residing in Japan on the Japanese economy and national life, and they are clearly stipulated in the Ministry of Justice Ordinance. On the other hand, with respect to application for change of the status of residence, Article 20 of the Immigration Control and Refugee Recognition Law stipulates that the Minister of Justice may "give permission only when he finds that there are reasonable grounds to grant the change of status of residence on the strength of the documents submitted" in addition to the fact that the applicant engages in activities that fall under the relevant status of residence in Japan. Furthermore, the article stipulates that "in the case of an application submitted by a person whose status of residence is Temporary Visitor, permission shall not be given unless the application is made based on a special unavoidable circumstance." Examination is carried out in line with these statutory provisions. (2) Publication of examination criteria The Ministry of Justice places the specific handling for some statuses of residence, including "Investor/Business Manager," on its website to promote clarification of the cases where permission is given. In addition, the ministry determines, in principle, the period of stay as three years. For example, however, the ministry determines the period of stay as "one year" in the cases where relevant business falls into the category of new business and the continuity of the business has to be confirmed, where it is necessary to confirm the continuity of the business over a short time due to failing financial condition of the business establishment, like in this case, specifically, annual sales of \17 million and a loss of \47 million, or where a business manager, etc. has conducted some sort of violation, etc. during the previous period of stay and the subsequent condition of residence has to be confirmed. (3) Clear indication of examination results and reasons thereof Regarding the notice of refusal for this case, the Immigration Bureau informed the applicant, in a written notice, of nonconformity to the requirements provided in Article 20 of the Immigration Control and Refugee Recognition Law. (4) Realization of immigration control reflecting the national policy In response to the recommendation made in the Third Report of the Council for Regulatory Reform in fiscal 2003 that the government takes measures to "expedite and simplify the examination of applications for a certificate of approval of the status of residence," we examine and dispose of applications concerning organizations, which are recognized as being unlikely to cause such problems as overstaying in consideration of the past achievements and scale, etc., in a short period of time, as applications concerning good-standing companies. The majority of applications are now processed in this manner. On the other hand, in examining applications, there are the cases where careful examination is required, for example, the case where there is doubt about the existence of the company itself. If necessary, the Immigration Bureau determines whether the applicant fulfills requirements for permission by conducting fact-finding survey to understand the actual condition of the company or by requesting the applicant to subsequently complete explanatory documents or submit a written explanation. In this case, time for fact-finding survey and certain period of time for the applicant to prepare additional documents are required. Hereby, examination results may get out later than in ordinary cases. (5) Regarding examination criteria for the status of residence "Investor/Business Manager" The status of residence "Investor/Business Manager" covers the case where a foreign national manages a company in which he/she invested in Japan. Not only for the said status of residence, foreign nationals have to necessarily engage in activities provided in the bottom column of the Annexed Table of the Immigration Control and Refugee Recognition Law or activities of a person with the civil status provided in the bottom column of the said Annexed Table in order to acquire the status of residence provided in the said Annexed Table. In examination, foreign nationals must be recognized as engaging in activities falling under relevant status of residence in Japan. Since recognition of the status of residence "Investor/Business Manager" is for foreign nationals who start business management in Japan, invest in business in Japan, or manage and administer business on behalf of a foreign national who did the above, these activities have to be continuously conducted. Therefore, the continuity of relevant business is an important factor in asserting that foreign nationals fall under the said status of residence. Continued deficit in the business managed and administered is a factor that raises questions in considering the continuity of the business. In addition, the Ministry of Justice Ordinance separately establishes criteria for the status of residence "Investor/Business Manager," and according to the said criteria, a business establishment has to exist in Japan. In the case of a leased business establishment, a contract is ordinarily concluded in the name of a company or its representative. In the case where a lease contract was concluded neither in the name of a company nor in the name of its representative, the Immigration Bureau cannot recognize that the applicant conforms to the requirement of securing of a business establishment unless an especially reasonable ground is indicated, though the Immigration Bureau may, in some cases, recognize no problem in terms of the securing of a business establishment. Reasons for refusal in this case are as described in the notice. If the Tokyo Immigration Bureau cited "slumping business and deficits" and the fact that "the office is not leased in the name of the principal" as reasons for refusal, we believe that the bureau considered whether the corporate entity would continue to exist and conduct investment/management activities, and then concluded that the bureau could not certainly recognize future continued activities (for the former reason). The bureau also concluded that it could not recognize securing of a business establishment (for the latter reason). (A reply on December 13, 2004) (1) Clarification of examination criteria The Immigration Control and Refugee Recognition Law specifically stipulates, in its Annexed Tables, activities in which foreign nationals should engage to achieve each status of residence. Regarding some statuses of residence, including "Investor/Business Manager," criteria that serve as requirements for landing permission are provided in express terms in the Ministry of Justice Ordinance. Though these criteria are relating to landing permission, we deal with applications for change of the status of residence and renewal of the period of stay in conformity to the case of landing permission. For this reason, Immigration Bureaus actually determine whether to permit change of the status of residence after examining whether activities in which the applicant intends to engage fall under activities stipulated in the bottom column of the Annexed Table of the Immigration Control and Refugee Recognition Law (whether to fall under the status of residence), whether such activities conform to the above-mentioned criteria (conformity to the criteria) and whether there are no problems with the past condition of residence (as mentioned in the related part of the Outline of Examination for Immigration and the Status of Residence as attached (= annexes omitted)), though the law stipulates that the requirement for permission of change of the status of residence is the presence of reasonable grounds to grant the change of status of residence. Of these requirements, the former two are specifically stipulated in the Immigration Control and Refugee Recognition Law and the Ministry of Justice Ordinance. On the other hand, there are no statutory provisions for the requirement of "no problems with the past condition of residence," but past violations and false applications are questioned in practice. (2) Publication of examination criteria Same as above. (3) Clear indication of examination results and reasons thereof Regarding reasons for refusal or non-issuance, the summary of reasons is to be described in a notice of refusal or non-issuance. Incidentally, regarding applications for change of the status of residence from "Temporary Visitor," Article 20 of the Immigration Control and Refugee Recognition Law is generally quoted as a reason for refusal since the article stipulates that "in the case of an application submitted by a person whose status of residence is Temporary Visitor, permission shall not be given unless the application is made based on a special unavoidable circumstance." At any rate, in terms of reasons for refusal, Immigration Bureaus give further specific explanation as appropriate or at the applicant's request, in addition to description in the said notice. (4) Realization of immigration control reflecting the national policy Although the criteria mentioned in (1) are provided in the Ministry of Justice Ordinance, according to the Immigration Control and Refugee Recognition Law, criteria shall be established "in consideration of factors including but not limited to the effect on Japanese industry and the general welfare" and after going through consultation with the heads of the relevant administrative organizations. In that sense, criteria will indicate Japan's policy for acceptance of foreign nationals at that time in consideration of requests, etc. in the related domestic administrative fields. (5) Regarding examination criteria for the status of residence "Investor/Business Manager" a) Whether to fall under the status of residence Each status of residence provided in the upper column of Annexed Table I of the Immigration Control and Refugee Recognition Law is the status set with the focus on activities in which foreign nationals engage in Japan, and it is granted on the premise that foreign nationals continuously engage in relevant activities during their stay in Japan. In this case, however, there are doubts about the continuity of investment/management activities to be conducted by the applicant due to the financial conditions of the company, such as continuance of a considerably large deficit compared to the capital amount and sales. b) Conformity to the criteria One of the criteria provided in the Ministry of Justice Ordinance regarding the status of residence "Investor/Business Manager" is that "a business establishment for running relevant business exists in Japan" for the business whose management and administration the applicant engages in. In this case, however, the intended purpose of the facility used as the main office is residential use according to the lease contract. In addition, the lease contract was concluded not in the name of the company but in the name of an individual. It is a matter of course that a facility held by a company as a business establishment is owned or leased by the company. Reasonable grounds are necessary to use a facility in the name of an individual as a business establishment. After confirming the condition of the relevant facility through fact-finding survey, the Immigration Bureau determined that the facility could not be recognized as actually functioning as a business establishment. Incidentally, the nominee of telephone subscription for the business establishment is also not the company but an individual. c) Past condition of residence The applicant made a false statement about employees when applying for the renewal of the period of stay on May 14, 2003, and the applicant's condition of residence is hardly good. (This complaint was reported to the 35th MAOC held on December 7, 2004. It was designated as one of the complaints to be individually deliberated in the problem raising process in fiscal 2004, as one of the individual complaints containing especially important issues. The MAOC held an Experts Conference on January 31, 2005 and formed opinions at the 36th MAOC on March 18, 2005. In response to this, the Office of Market Access decided to take the following actions. Thereby, the processing of this complaint was completed.) "Policy Actions on Market Access Issues" (March 24, 2005; decided by the Office of Market Access) (Extract) The responsible ministry will take the following actions with respect to criteria for the status of residence of foreign business managers. (1) The ministry will explain and publish specific cases in terms of the necessity of the continuity of business in conducting activities under the status of residence "Investor/Business Manager." (2) (i) The ministry will again thoroughly inform Immigration Bureaus that the continuity of business should be judged in a comprehensive manner. In addition, (ii) regarding criteria for securing of a business establishment as stipulated in the Ministry of Justice Ordinance, the ministry will explain and publish specific cases where Immigration Bureaus judge that a business establishment is secured. Moreover, (iii) the ministry will prepare examination guidelines for the cases where Immigration Bureaus judge that a business establishment is secured when the establishment is also used for residence. (3) When judgement of refusal (or non-issuance) is made, more detailed reasons will be described in a notice. (i) The ministry will again thoroughly inform Immigration Bureaus of the purport of the guidelines for the scale of investment, which were prepared in response to the decision by the Office of Market Access in March 2000, and will eliminate discretionary administration wherever possible. Moreover, for thorough enforcement of the purport, (ii) the ministry will promptly amend the Enforcement Regulations so as to include documents to confirm the amount of investment in the materials that applicants have to submit in applying for the status of residence "Investor/Business Manager."
Classification of Processing	A	Directions	I-b
Remarks	A written reply was made on November 8, 2004. A written reply was made on December 13, 2004. Considered in the problem raising process in fiscal 2004. The complainant acquired the status of residence "Investor/Business Manager" on March 18, 2005 as a result of filing a reapplication.

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