The process surrounding the promulgation of the draft Code also is troubling: the original public comment period was only two weeks. Nevertheless, the International Franchise Association and other interested parties submitted critical comments, and the Ministry has now agreed to redraft the proposed Code. However, the revision will not be published for additional comments and is likely to be enacted into law later this year.

Philip F Zeidman
Rudnick, Wolfe, Epstein & Zeidman
Washington, DC