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TTB Expands Electronic Filing of Forms and Supporting Documents

The Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau is amending its regulations on document filing and recordkeeping to allow more electronic submissions, in an interim final rule that takes effect April 28. Treasury Decision TTB-119 allows for electronic copies of documents and forms when the originals aren’t available in an electronic format, and provides for the electronic submission of documents required by TTB to other federal agencies, including CBP.

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Electronic Submission of Non-Electronic Docs

As part of its move to electronic communications and transactions, including its Permits Online and COLAs Online systems, TTB ‘s interim final rule allows for electronic submission of documents that may not be in electronic format in their original form. This will let regulated industry file supporting documentation and certain forms that require multiple signatures electronically, said TTB.

Multiple signatures. The interim final rule will let submitters file forms that require more than two signatures, such as powers of attorney and bond forms, electronically with TTB. The party required to submit the form will be able to file an electronic copy showing all required signatures. A certification will be required that the copy is exact and has all required signatures, and the original copy will have to be maintained at the filer’s place of business.

Supporting documents. TTB is also allowing filers to electronically submit supporting documentation to the agency when the originals are not available in electronic format. For example, this would include commercial documents that must be submitted to satisfy reporting requirements, said TTB. As with documents having multiple signatures, a certification will be required that the copy is exact, and the original copy will have to be maintained at the filer’s place of business.

Streamlined Process for Accepting New Electronic Docs

TTB’s interim final rule removes the requirement that TTB must authorize electronic filing of new types of forms and documents through a Federal Register notice. It is also removing the requirement that it publish a Federal Register notice when it allows electronic recordkeeping for a particular document. The agency says these changes will give “greater flexibility for TTB to provide for the use of electronic forms.”

Electronic Submission to Other Agencies

Finally, TTB’s interim final rule provides that documents required by TTB may be submitted to other agencies in electronic form, as long as the other agency authorizes electronic submissions. As an example, TTB said this will allow documents related to the importation of TTB-regulated commodities to be submitted to CBP in electronic form.

(See notice for other changes, including changes to requirements for containers of distilled spirits from Puerto Rico or the U.S. Virgin Islands, etc.)

(Federal Register 03/27/14)