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The Government of Japan hereby submits the comments on the
program of amendment of the rule of the Social Security
Number (SSN) announced by Social Security Administration (SSA)
on March 26, 2003.
- In the United States, presentation of SSN is required
in principle on various occasions in daily life such as
application for a driver's license or a credit card,
opening a bank account, and signing a lease contract for
housing. As a result, there are many cases where
dependants of Japanese staff working at Japanese firms in
the United States, who are legal foreign residents with
nonemployment-based visas and cannot obtain SSN, are
forced to inconvenience in the daily life. The Government
of Japan recognizes that such problems result from SSN
virtually being the sole measure for identification in the
United States. Consequently, The Government of Japan above
all requests SSA to amend the rule so that legal foreign
residents with nonemployment-based visas can obtain SSN.
- One of the most serious obstacles they face caused by
the lack of their entitlement to obtain SSN is the
difficulty to acquire a driver's license, for which some
states still admit only SSN as the measures of
identification. Since it causes critical inconvenience to
live without automobile in the United States, the absence
of SSN for the dependants of Japanese staff workers
eventually hampers their daily life to a significant
extent.
The Government of Japan appreciates that most states have
introduced alternative measures of identification on
issuing driver's license as a result of the recommendation
by SSA to do so. Some state governments, however, still
require the applicants of driver's license to present SSN.
If SSA enforces the proposed amendment of the rule and the
issuance of SSN ceases due to an explicit regulatory
demand, legal foreign residents with nonemployment-based
visas will be completely unable to obtain a drive's
license in these states.
Therefore, while it may be even if it is difficult to
realize the proposal mentioned in the paragraph 1 above
promptly, the Government of Japan strongly requests that
the Government of the United States consider the following
steps, as tentative measures.
(1) The Government of the United States should strongly
request all the state governments which require the
presentation of SSN in applying for a driver's license to
introduce specific alternative identification measures
available to legal foreign residents who cannot obtain SSN.
The Government of the United States, above all, should
strongly request the state of Illinois where they still
face the most serious obstacles to reform its system as
quickly as possible. In addition, the Government of the
United States should petition that the state governments
strive to innovate the measures which are available
practically and lightly to all legal foreign residents, in
case of introduction of alternative measures for
identification.
(2) The Government of the United States should suspend the
enforcement of the proposed rule, until all state
governments introduce alternative measures for
identification.
(3) The Government of Japan would like to urge the
Government of the United States to recall the fact that
the Government of Japan has repeatedly articulated these
requests in course of bilateral dialogues such as the
Japan-U.S. Enhanced Initiative on Deregulation, the Japan-
U.S. Regulatory Reform and Competition Policy Initiative
and the Investment Initiative, and anticipates that the
Government of the United States will earnestly consider
the above-mentioned recommendations.
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