점포행정을 통해 본 전후 일본의 재량적 금융행정

Abstract

This paper analyzes the features and changes in the branch licenses(店舗行政) in Japan, as an organic part of the financial administration, called 'the convoy-fleet system' . It is no exaggeration to say that the history of branch licenses is the history of financial administration. The discretionary financial administration through administrative guidance such as Tsutatsu(通達, internal orders used as a communication tool between high level officials and their sub ordinates) was an institutional framework through which competition restrictive regulation such as regulation on the businesses of financial institutions, regulation of deposit interest and branch licenses which was imposed. The Ministry of Finance wielded very large discretionary authority over branch licenses and the results were highly efficient. Although the discretionary financial administration, represented by branch licenses, was effective in preventing financial crisis in prewar days, it could not evade the financial crisis of the 1990s. The competition restrictive regulation based on discretion such as branch licenses was abolished in principle by financial system reform process after the financial crisis of the 1990s. And the deposit insurance system based on a rule and the regulation system centering on soundness regulation are under construction. But drawing on ‘the path dependence’ and ‘hysteresis’ approach, this study argues that it is unlikely that the Japanese financial system reform will converge on the American financial model.