1513-0004 Ss (10-31-2012)

OMB Control Number 1513-0004 - Supporting Statement, page 4

DEPARTMENT OF THE TREASURY

ALCOHOL AND TOBACCO TAX AND TRADE BUREAU

Supporting Statement – Information Collection Requirement

OMB Control Number 1513-0004

TTB F 5030.6 Authorization to Furnish Financial Information and Certificate of

Compliance

A. JUSTIFICATION.

1. What are the circumstances that make this collection of information necessary and what legal or administrative requirements necessitate the collection? Also include the following: Align the information collection to Treasury’s Strategic Goals, Line of Business/Sub-function, and IT Investment, if one is used.

Applicants for alcohol and tobacco permits are required by regulation to provide information concerning money used to finance the business. The Right to Financial Privacy Act of 1978 (the Act) limits access to records held by financial institutions and provides for certain procedures to gain access to information (12 U.S.C. 3404).

The Act also requires that government agencies certify to the financial institutions that they have complied with all provisions of the Act (12 U.S.C. 3404). TTB 5030.6 acts as both a customer authorization that provides the agency employee authority to receive the information and as the required certification to the financial institution.

The other legal citations for this information collection are 12 U.S.C. 3403, 27 U.S.C. 204 and 205, and 26 U.S.C. 5712; and the regulatory cite is 27 CFR 1.24.

This information collection is aligned with:

Treasury Strategic Goal: None.

Line of Business/Sub-function: Law Enforcement/Taxation/Substance Control.

IT Investment: None.

2. How, by whom and for what purpose is this information used?

Anyone who owns or makes an investment in a business that requires a permit or authorization from TTB to operate is required to prepare and submit TTB F 5030.6. The applicant must complete Section A of the form to authorize access to the information.

Verification of the financial background information is an important step in the qualification process. Our personnel verify this information as part of the application inspection. We verify this information for the following reasons:

1. To ensure that the applicant, by reason of his/her business experience, financial standing, or trade connections, is likely to commence operations within a reasonable period and to maintain operations in conformity with Federal law.

2. Insufficient funds from acknowledged investors or unusual transactions in accounts could be an indication of hidden ownership by someone ineligible for a permit.

3. If interest in retail licenses or property used by retailers is disclosed, we may discuss potential violations of 27 U.S.C. 205(b) with applicants.

The customer’s authorization is required to verify information provided and to enforce the law.

3. To what extent does this collection of information involve the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology? What consideration is given to use information technology to reduce burden?

TTB has approved and will continue to approve, on a case-by-case basis, the use of improved technology for the maintenance of this information.

4. What efforts are used to identify duplication? Why can’t any similar information

already available be used or modified for use for the purposes described in Item 2 above?

TTB F 5030.6 collects information that is pertinent to each respondent and applicable to his/her specific situation. As far as we can determine, similar information is not available elsewhere.

5. If this collection of information impacts small businesses or other small entities,

what methods are used to minimize burden?

All entities, regardless of size, are required by statute to complete this form. There is no alternative or manner in which to reduce the burden to small businesses.

6. What consequences to Federal program or policy activities and what, if any, technical or legal obstacles to reducing burden will occur if this collection is not conducted or is conducted less frequently?

If respondents did not complete this form, TTB would have no way of verifying the respondent’s financial standing and would be unable to complete the application process. Respondents complete this information only as often as necessary to comply with the statute.

7. Are there any special circumstances associated with this information collection that would require it to be conducted in a manner inconsistent with OMB guidelines?

There are no special circumstances associated with this information collection.

8. What effort was made to notify the general public about this collection of information? Summarize the public comments that were received and describe the action taken by the agency in response to those comments.

A 60-day Federal Register notice was published for this information collection on Friday, June 29, 2012, 77 FR 38886. The notice solicited comments from the general public. TTB received no comments.

9. What decision was made to provide any payment or gift to respondents, other than remuneration of contractors or grantees?

No payment or gift is associated with this collection.

10. What assurance of confidentiality was provided to respondents and what was the basis for the assurance in statute, regulations, or agency policy?

We do not provide specific assurance of confidentiality for this information collection requirement. The confidentiality of information provided on this form is protected by 26 U.S.C. 6103, if it is tax return information, and the information is generally exempt from disclosure under the Freedom of Information Act, exemption (b)(4).

11. What justification is there for questions of a sensitive nature?

We do not ask questions of a sensitive nature in this collection.

12. What is the estimated hour burden of this collection of information?

The burden hours remain at 500. We estimate that there will be 2,000 respondents that will complete this form in 15 minutes, once during the initial application process.

13. What is the estimated total annual cost burden to respondents or recordkeepers

resulting from this collection of information (excluding the value of the burden hours in

Question 12 above?

We do not associate any cost with this collection.

14. What is the annualized cost to the Federal Government?

Estimates of annual cost to the Federal Government are as follows:

Printing $ 400

Distribution 500

Clerical Costs 409

Other Salary (review 534

supervisory, etc.)

TOTAL $1,843

15. What is the reason for any program changes or adjustments?

There are no program changes or adjustments associated with this collection.

16. Outline plans for tabulation and publication for collections of information whose results will be published.

The results of this collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of this information collection, what are the reasons that the display would be inappropriate?

We will display the expiration date of OMB approval for this collection.

18. What are the exceptions to the certification statement?

(c) See item 5 above.

(f) This is not a recordkeeping requirement.

(i) No statistics are involved.

(j) See item 3 above.

B. Collection of Information Employing Statistical Methods

This collection does not employ statistical methods.