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B-196398 1 (1982-02-18)

handle is hein.gao/gaobachim0001 and id is 1 raw text is: 
                     COMPTROLLER GENERAL OF THE UNITED STATES
                                 WAHiNGTON D.C. .ad                         5I17
        Y   \February 18, 1982

B-196398


The Honorable Peter W. Rodino
Chairman, Committee on the Judiciary
House of Representatives


Dear Mr. Chairman:

     This is in response to your request for comments on H.R. 4774, 97th
Congress, 1st Session, a bill which, if enacted, would revise, codify, and
enact without substantive change certain general and permanent laws related
to money and finance, as Title 31, United States Code, Money and Finance.
We welcome the efforts of the revisers to standardize and update the language
of many ancient and arcane statutes and to eliminate laws which have become
obsolete with the passage of time or superseded by later enactments. In-
evitably, however, in a revision of so vast a scope, errors of omission or
commission creep in and inadvertently change the substantive law.

     For many months, my staff has worked with the revisers on an informal
basis, explaining our concerns and proposing changes or modifications. Many
of these have been accepted and we are very gratified. There is still a
residuum of problems which we have addressed in the enclosed comments on
specific provisions of the bill, accompanied by some recommended language
changes.

     A few of the recommended changes are extremely important to us, because
without them, a great many Comptroller General legal decisions which rely on
provisions of existing law now proposed to be omitted will be undermined. For
an example in this category, see our discussion of proposed section 1702, and
its effect on the bona fide needs rule.

     There are some other sections in which the coverage of existing law is
inexplicably narrowed. For example, the District of Columbia is excluded by
the terms of the proposed code from the application of certain provisions of
law which currently apply to it. On the other hand, the proposed code still
lists the Federal Housing Administration as a wholly owned Government corpora-
tion even though it has not been a separate organizational entity since 1965.

     These types of changes are grouped together in Part I of our comments
(without regard to the order of presentation in the bill). We urge you to
give serious consideration to the adoption of all the recommendations in this
category.

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