View ICR - OIRA Conclusion



1513-0014 201301-1513-001
Historical Active 201011-1513-006
TREAS/TTB
Power of Attorney
Revision of a currently approved collection   No
Regular
Approved without change 05/31/2013
Retrieve Notice of Action (NOA) 01/28/2013
Prior to its next submission for renewal, OMB would like TTB to address the public comment suggesting that the form be amended to recognize the representation of industry members by law firms instead of only individual attorneys. If TTB concludes that amending the form in this way would be legally impermissible, problematic and/or unnecessary, Treasury shall provide supporting justification for this in the supporting statement of its next submission. Requiring representation by only individual attorneys could potentially be problematic; if the attorney representing the industry leaves the law firm that the industry uses, they are still considered by TTB as the representing attorney. This could lead to multiple issues with improper disclosure (i.e. sharing of proprietary information), and administrative burdens imposed on industries of having to keep track of individual attorneys at the law firms they use. We feel that TTB needs to properly address these issues before its next submission.
  Inventory as of this Action Requested Previously Approved
05/31/2014 36 Months From Approved 05/31/2013
10,000 0 10,000
3,250 0 3,333
0 0 0