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Langdon Guenther

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  1. Hi Coach, I'm retired from TTB's NRC here in Cincinnati where all applications are processed. Question 1: You do not need a bond to receive spirits transferred in bond. Question 2: If you filed your original DSP application by paper, you'll have to mail a completed TTB F5100.16 to the NRC. The latest edition, 11/2016, is available at ttb.gov. If you filed your application using Permits Online (PONL) you will submit an amendment via PONL. It's pretty straightforward. If you have any issues or further questions, contact me at langdonguenther@gmail.com and/or 513-257-9378. A caveat: PONL filers will receive an approved TTB F5100.16 that has an edition date of 10/2009, instead of 11/2016. It's another PONL glitch that has not been fixed yet. This has caused some concerns and issues with DSP's that are shipping the spirits. Get your request in as soon as possible. Processing time on these requests at the NRC was recently 2-3 weeks. Hope this helps. Langdon
  2. Hi - My name is Langdon Guenther and I'm retired from TTB. I worked at the National Revenue Center (NRC) here in Cincinnati where we processed permit applications for all 50 states in all commodities. I worked in the distilled spirits section. I can walk you through exactly what you have to do to terminate your bond because of the PATH Act and the lower FET rates and because you filed a paper application (pre-PONL). Phone my cell at 513-257-9378 and/or email me at langdonguenther@gmail.com and I'll be happy to help you gratis. Langdon
  3. I'm retired from TTB and worked my entire time at the National Revenue Center (NRC) here in Cincinnati in the Distilled Spirits Section. In 1999, when I started working for TTB's predecessor agency, ATF, the NRC processed about 4 craft distillery applications for all 50 states. We all know about the exponential growth that was soon to begin. I answered many incoming phone calls from folks inquiring about the DSP application process. I would tell them that their premises should be "essentially complete" before submitting their application. An ATF Inspector was assigned to conduct a field inspection on all of those early applications. Most DSP Basic Permits were issued within 30-60 days. Processing times certainly have changed since my retirement from TTB. The most recent statistic shows 184.82 days for a DSP Basic Permit. One might say that a 6 month processing time is an impediment to business. I am an independent consultant now and I advise clients to get their application submitted 6 months before their premises are completely built out and ready for production, processing and/or storage of distilled spirits. You should have most of your major equipment ordered when your application is submitted. Try to get the serial numbers from the manufacturer. If they are not available yet, or if any equipment will not have a serial number, assign a serial number yourself. The best advice I can give folks is to check with all zoning authorities and fire departments to ensure that they are good with your proposed DSP premises and operations before signing a lease agreement or purchasing the premises.
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