Who is the transferor and who is the transferee in the case of an exchange transaction? The sequence of physical custody is from terminal to truck to retail outlet, but the sequence of legal custody is from the terminal to exchange partner to marketer to

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Any party who is receiving title or custody of the delivery would be considered a transferee, any party who relinquishes title or custody would be considered a transferor and any party who both receives and relinquishes title or custody would be both a transferee and a transferor.

All transferors are responsible to provide all of their transferees PTD's containing the appropriate information. In some circumstances (where custody and title are being delivered to the same subsequent parties), it may be possible to utilize just one document that is updated each time the delivery is transferred. But the most appropriate way to meet PTD requirements is to include the PTD information on documents currently used to memorialize the transfer of title or custody. (7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (333 pp, 18.17 MB, EPA420-R-03-009, July 2003)