Transfer in Bond Application Turnaround

[Sator Square Distillery]

I wasn't about to find this anywhere else on the forums or on the TTB website under processing times. Does anyone have a rough idea how long it takes for the TTB to approve a transfer in bond application once it's submitted?

[Julius]

95 day for our last TIB approval. Multiple follow ups were required...

[Huffy2k]

I believe it only took a few weeks for our TIB to be approved.   Looks like I submitted application on 7/14/2017 and received approval on 7/25/2017.

[Silk City Distillers]

Never had a TIB take more than a few days...

[indyspirits]

I'm with Silk on this one. A few days.  Is this first one you've done? Did you have to get a new bond?

 

[Sator Square Distillery]

I'm not required to carry a bond now, I was under the required tax threshold and they gave me an exemption. The transfer to me would still put me well under, it's just a few barrels really. But this is the first transfer in bond that I've done. I submitted it back on 10/26, so it would be 2 weeks now it's sitting pending review. I guess I thought it wouldn't take this long? How long would you wait to follow up if it was you?

[Airman700]

In our experience it is all dependent on the ttb agent assigned. We submitted 2 a day apart 3 months ago. They were assigned to two different officers. The second one was approved in 8 days. The first one sat idle for 30 days till we we made an inquiry. It was approved the next day.

 

Tim

[sandytoes]

Only done a couple but it has been one or two days for us to get approval each time.

[dhdunbar]

Sometimes it is quick ; sometimes it isn't.  I can't explain that.  I have had the thought that they may batch process them, so if you go in the day before they process the batch, bingo, you are a winner, but if you go in the day after, oops, you gotta  wait.  I do not know this.  It  is a guess based on the fact that there are no gray areas they have to navigate.  The review can't take more than a few minutes.  The questions : (1) "Do yo need a bond,?"  If no proceed to (3).  If yes,  then (2)"Is the bond sufficient?"   If no, reject.  If yes, proceed to (3), "Are the names, addresses, and permit numbers all correct according to TTB's database?".  If so, push the approve button.  Of not, reject.  So I can';t imagine someone taking a month to review one unless they delay the review and process them by batch.  Al;l of which doesn't matter, because the only answer is that it is unpredictable and after two weeks, I would ask.

[Sator Square Distillery]

I called the TTB this morning to see what the holdup was. I got someone on the phone right away. I was told that there was some sort of change in the recent past which doesn't let the specialists see which permit amendments are bond transfer or other requests for changes. So they just do them as they come in in order they get them. Not sure if that's true. But they told me they'd send a request for a quicker review over to who has the request. It's been a day shy of 3 weeks for the bond transfer, that does seem like too long of a time to wait for a simple purchase order.

[dhdunbar]

1 hour ago, Sator Square Distillery said:

I called the TTB this morning to see what the holdup was. I got someone on the phone right away. I was told that there was some sort of change in the recent past which doesn't let the specialists see which permit amendments are bond transfer or other requests for changes. So they just do them as they come in in order they get them. Not sure if that's true. But they told me they'd send a request for a quicker review over to who has the request. It's been a day shy of 3 weeks for the bond transfer, that does seem like too long of a time to wait for a simple purchase order.

I think that may not be true, because amendments of different types seem to get different tracking numbers.  Looking over my submissions, it appears that the permits online system assigns a number in the form 2018-TIB-00123 to transfers in bond; 2018-USP-00123 to changes in the post office address,  etc., so that the middle three letters distinguish between the different types of amendments.  If I can see that in the amendments I submit, then I think the specialists can see it at their end too.

However, if it is true, and TTB specialists cannot tell whether an application is for approval of a transfer in bond, they also cannot see changes in powers of attorney, signing authority, post office address, additions of trade name, the addition of a new still, etc...  Applications that take 15 minutes to approve, once in someones hands, can end up taking months.   That's nuts and they can do something about that.

I suspect the truth is something else.  A couple of years ago, label approvals were taking something like 50 days to get processed, giving rise to general dissatisfaction because of seasonal products, the inability to plan marketing campaigns, etc.  Because people took arms and complained,  rather than suffer slings and arrows of outrageous fortune, as it were, TTB got an increase in its budget to specifically fund more specialists to handle labels.   What could not be reasonable resolved internal was resolved by budget increase. 

The blood and turnip rule applies here.   TTB's NRC is asked to do more (look at the increase in the number of businesses that are submitting new and amended applications) with less (apart from the earmarked funds for label approvals, TTB's budget in constant dollars has decreased since 2000).  Notions of cutting government spending by 5% across the board can drive poverty into bankruptcy.  Where that critical point is passed, no one can tell, but the notion of more with less will fail at some point.  If it didn't, you could all operate your distilleries for 50% less than it is costing you now.  

If the specialists can't tell one amendment type from the other, that is a systemic problem that can be corrected internally.  If they are nearing the critical point where things break, then the only solution is more people to do the job that congress requires them to do. Am I suggesting that you write your congressman saying, "Fund TTB so it can do the job you require it to do," like DISCUS and the Wine Institute and the Brewers Association did a few years ago?  You bet I am.  Congressmen will listen to constituent-waves, and there are a lot of you out there.  There are more than 900 wineries, god only knows how many brewers, and more than a few dozen distilleries in Washington, where I live.  If they all work in concert, that would be a wave that might move congress to give TTB the funds necessary to let you carry on your business.  I'll guarantee you the flood will get your congressman's attention.

[Sator Square Distillery]

It looks like shaking the tree worked. I got my approval within an hour of making that phone call. I wish I'd done that last week, but it is what it is. Thank you all for chiming in. I'd say that it's totally worth calling the TTB if things seem to be taking too long.