Clarification on Review of Draft Applications:

Increasing demands on the resources of the FTZ Staff require us to clarify and refine our practice regarding the review of draft applications.

For applications which outside parties are preparing for the FTZ Board, the FTZ Staff has encouraged the submission of a single copy of a draft version of the application. In this manner, applicants can be informed of deficiencies requiring correction (or information requiring supplementation) and make appropriate changes to application prior to the submission to the Board of the completed application (with required multiple copies). The FTZ Staff providing feedback on draft applications has proven beneficial both for applicants and to the FTZ Staff (eliminating the need to return multiple copies of an application requiring correction or supplementation). However, the FTZ Staff is increasingly receiving very rough drafts of applications and also being presented with multiple rounds of revised draft versions in a manner that has a significant negative impact on staff resources.

The key intent of the FTZ Staff’s review of draft applications is to provide feedback – on an essentially complete application – so that an applicant can be confident in then making multiple copies and submitting the original and copies to the Board. To enable the continued review of draft applications within current resource constraints, the FTZ Staff will now be applying the following policy:

In order for the FTZ Staff to review a draft application, the application must be complete with the possible exception of the grantee’s transmittal letter and resolution. The allowable exception for the transmittal letter and resolution may enable certain applicants to have the FTZ Staff review an application for completeness while waiting for the resolution or transmittal letter to be finalized. The FTZ Staff’s review of the draft application will also enable applicants to receive staff feedback prior to completing the required number of copies of an application for submission to the Board (thereby reducing the possible need to make changes to multiple copies, including having the FTZ Staff return copies to the applicant so that such changes can be made).

Given FTZ Staff resource constraints, applicants need to allow a minimum of two weeks for review of draft applications.