871.51/596

The Minister in Rumania (Jay) to the Secretary of State

No. 689

Sir: I have the honor to report that, having learned that the Rumanian Government is under pressure to extend again for a further period of three months the Term of Grace Law, which would otherwise expire on December 15th, I addressed yesterday a Note to the Minister for Foreign Affairs repeating our views on the subject and protesting against a further extension.

As will be seen from the copy I enclose, I have endeavored, while briefly reiterating our views, to lay emphasis on the concern felt by the Department, to indicate possible consequences and finally to place on record in writing before the expiration of the present extension an official protest against any further renewal.

I have laid stress on the impropriety of affording protection to the solvent debtor rather than on the discriminatory nature of the legislation—a contention vigorously denied in both Government and commercial circles.

The Minister for Foreign Affairs is well aware of the importance attached to the entire subject by our Government, especially as only last week (November 27th) during a long informal conversation in regard to all the questions at issue I allowed Mr. Duca to read the actual views of the Department which are so fully and clearly expressed in its Instruction No. 319 of November 7th last.65

It must be admitted that the Rumanian Government finds itself in a very difficult position, as collective commercial agreements [Page 661] have been concluded with British, French, Belgian, Italian, Swiss, and possibly other creditors, which obligate the Government to prevent by legislation foreign creditors on whose behalf no collective agreements exist, from obtaining execution of judgment.

If the Rumanian Government were to permit American creditors to obtain unconditional satisfaction of their claims, it would undoubtedly receive vigorous protests from the foreign governments concerned, whose nationals have been assured, by Rumanian legislation, protection against any such favored treatment to creditors of nations which have not concluded such agreements.

I fear that even if the Term of Grace Law is not given another extension, it will in practice be found impossible on one pretext or another to secure actual execution of judgments. Moreover, I understand that a “loi d’imprévision” (A law giving Courts discretionary power to grant a term of grace to debtors whose inability to meet their obligations is shown to be the result of circumstances beyond their control), such as apparently exists in certain countries observing the Code Napoleon, may be shortly incorporated in the Rumanian Civil Code, thus permanently replacing the Term of Grace Law.

The entire question of the payment of commercial debts is exceedingly involved. It is most difficult to ascertain at all definitely just how the laws and regulations are being applied, particularly in view of the influence which (it is widely believed) the Government is privately exercising upon the Courts.

The Department will have received the memorandum drafted by the Delegate of the Bucharest Chamber of Commerce which was transmitted in the Legation’s Despatch No. 676 of November 7th,66 and which covers very fully the situation from the Rumanian point of view.

I enclose a copy of a letter which our Acting Commercial Attaché has kindly written me at my request,66 giving me his personal survey and opinion of the question. As will be seen, Dr. Van Norman has gone over the entire subject with great care.

I have [etc.]

Peter A. Jay
[Enclosure]

The American Minister (Jay) to the Rumanian Minister for Foreign Affairs (Duca)

No. 116

Mr. Minister: At the instance of my Government I have the honor to address Your Excellency concerning a matter which has been made [Page 662] by the Legation the subject of previous representations to the Rumanian Government. I refer to the so-called “Term of Grace” Law, originally promulgated on May 17, 1923, and which has been extended from time to time.

Although I have on several occasions brought to Your Excellency’s attention the objections of my Government in connection with this Law, I am now instructed to reiterate and explain more fully the basis of these objections.

It is clear that this “Term of Grace” Law prevents private American creditors from obtaining payment of debts due them in American currency even when the private Rumanian debtor is solvent, unless they are willing to submit to certain arbitrary terms dictated by the Rumanian Government. My Government is unable to accept the action of Your Excellency’s Government in applying the terms of this Law to all debts due by Rumanian nationals to American citizens regardless of the solvency of the debtor and it moreover considers this legislation discriminatory inasmuch as it does not apply to all debts due in Rumania, but merely to those due in a strong currency. My Government views this legislation as an improper and arbitrary governmental interference with the right of private contract, since, irrespective of the financial capacity of the debtor to pay, it subordinates payment to arbitrary terms imposed by the Government of the debtors—an interference for which the Rumanian Government might be held liable to American citizens suffering damage by reason of its action.

I am therefore instructed to insist that Rumanian Laws and regulations should be such as to permit American creditors freely to obtain payment from solvent Rumanian debtors.

As it appears that the last extension of the “Term of Grace” Law expires on the 15th of this month, I must once more reiterate my Government’s formal request that this Law be either not again extended, or else that it be modified in such a way as to permit American creditors freely to obtain payments due to them from solvent Rumanian debtors.

I avail myself [etc.]

Peter A. Jay
  1. Ante, p. 637.
  2. Not printed.
  3. Not printed.