To ensure a consistent and predictable business climate for Michigan taxpayers, agency guidance and rulemaking must adhere to the Administrative Procedures Act (APA). Too often, the Michigan Department of Treasury has issued “notices,” “policy directives,” “bulletins,” “frequently asked questions” and other “guidance” that is not binding on the agency and has not been vetted appropriately through the APA.

MMA Position: Agency guidance and the rulemaking process in the Treasury Department must adhere to the Administrative Procedures Act to ensure a consistent and predictable business climate.