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Outstanding gasoline exchange balances are commonly closed out between trading partners on an accounting basis because they are too small for an economic physical shipment. These "book transfers" do not in themselves cause the transportation or storage of product. Is it correct to assume that these activities are not subject to a requirement for PTD's?

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The PTD requirements refer only to the transferring of custody or title of any reformulated gasoline, RBOB, or conventional gasoline. If these "book transfers" involve the transferring of custody or title of such fuels then the PTD requirements would be applicable.

The PTD information could be included on whatever documents are currently being used to memorialize these transactions for business reasons. (7/1/94)

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