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THE ALLIANCE OF ALCOHOL INDUSTRY ATTORNEYS & CONSULTANTS

How does the federal shutdown affect my liquor license application?

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Category: TTB, brewery, winery, wholesaler, Tax and Trade Bureau

01.02.19

As of today, January 2, 2019, the continued closure of the federal government should have very little impact on pending liquor license applications. If the federal shutdown continues for much longer, we expect that backlogs will persist, even after a budget is approved and Tax and Trade Bureau (TTB) workers return to their jobs.

One thing is clear, though: no new applications will be approved until the budget impasse is resolved. That includes transfers in bond, formulas, COLAs and anything else that requires approval by TTB.

Keep in mind that state and local governments are not affected by the federal shutdown.  There are no delays with the Tennessee ABC or local beer boards.

We also understand that the IRS is continuing to process applications for new federal identification numbers, known as EIN’s, which are required for every new company.

Because of the holidays, we expect that TTB is not too far behind in its review of basic permits, DSP’s, brewer’s notices, TIB’s and other federal permit applications. Both the public and private sector were sufficiently distracted by Santa, Father Time and other holiday festivities.

The TTB on-line filing system seems to be functioning as normal. We encourage folks to continue filing applications online, with the understanding that no one is going to review them until TTB returns to work.

A prolonged shutdown of the federal government will lead to a significant backlog in application review, which we expect to continue long after TTB workers return to their desks. Before the shutdown, TTB indicated the following normal processing times for applications:

Type Average days to process permits
Brewery 86
DSP 71
Winery 85
Wholesaler 73

It is fairly reasonable to presume that for every business day TTB staff is not working on applications, the review time will increase by another day.

This has to be particularly disappointing for TTB workers, who have been successfully toiling for months to reduce the backlog of applications and approval times.

Conjures up a Styx classic:

We wish our friends at TTB well and know workers look forward to a speedy return to the building mountain of applications.

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