Catering conundrum created by Tennessee RLPS
The Tennessee ABC’s fancy new online filing system known as RLPS has changed the landscape for liquor licensing in Tennessee. The system generally works well.
Notices of catered events, however, present an opportunity for the system to do better.
Obtaining a catering license works like any other liquor license application. Once the catering license is issued, the problem begins for many caterers.
In order to file a notice of catered event, the person filing the notice must have access to the full license record. A notice of catered event essentially creates an amendment to the catering license. This means, if an assistant manager is tasked with filing notices of catered event, the assistant manager can also go in and change the ownership, criminal history disclosure of owners or otherwise amend the entire catering license.
We do not see this as a problem for mom-and-pop operations where mom and pop own the catering business and file their own notices of catered event.
The real issue is for larger companies that hold catering licenses. We do not recommend that on-site managers be granted access to RLPS for purposes of filing notices of catered event. Even if the on-site manager is not malicious, it is far too easy to “mess up” the RLPS record. Because the RLPS system contains disclosures upon which the license is statutorily based, even inadvertent amendments can affect the underlying qualification of the applicant to hold a license, potentially causing disclosure issues with the ABC and leading to sanctions.
According to the ABC, this is an RLPS system limitation that cannot easily be fixed. Allowing an on-site manager to file notices of catered event, without having access to the rest of the license record in RLPS, is going to require an upgrade to the underlying software that powers RLPS.
Another anomaly with filing notices of catered events is the amendment process. A notice of catered event is an amendment to the liquor license in the RLPS system. As an amendment, the status of the amendment – the notice of catered event – will show up as “In Review,” as if the notice of catered event needs approval. We have been assured that the ABC is not approving catering notices. It is just an RLPS thing.
We advise folks to disregard the “In Review” flag and know that once a notice of catered event is properly filed, no further action is required.
Sick and tired of Christmas songs, how about a little Weird Al’s Eat It, courtesy of our friend Willa:
So eat it
I don't care if you're full
Just eat it, eat it
Open up your mouth and feed it
Stay tuned for more developments with RLPS.
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