Does EPA make any distinction in terms of timeliness between PTD's which memorialize a transfer of title as opposed to those which memorialize a transfer of custody? For example, exchange statements detailing liftings by an exchange partner ordinarily are
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.77 does not distinguish between transfers of custody and transfers of title. Nevertheless, EPA believes the two situations may be different in terms of the timing necessary for PTD information. In the case of transfers of custody, the…