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Industry Circulars 19-2 Attachment C

Change in Proprietorship:  Permits Online Instructions for Filing Permit Applications and Requests for Acceptance in the Temporary Voluntary Disclosure Program Under TTB Industry Circular 2019-2

TTB Industry Circular 2019-2
Attachment C

All eligible industry members can file the documents for this Temporary Voluntary Disclosure Program electronically through Permits Online, even if they have not used Permits Online before.  Using Permits Online allows TTB to receive and process the documents more quickly, and provide status updates more easily.  If you have not yet registered for Permits Online, instructions are included below, and once you have registered, you can use Permits Online for your future permit-related submissions with TTB.

Getting Started

Follow these steps before you use Permits Online to submit your application and request to be accepted into this Temporary Voluntary Disclosure Program.  Click the boxes to view detailed instructions for each step:


  1. Ensure you have authority to submit the application

    In order to submit an application and request, you must have legal authority to act on behalf of or sign documents for the business entity for which the application is being submitted.

    For additional information on who has authority and what documentation is required, see:

    Who may submit applications to TTB through Permits Online?
  1. If you’ve never used Permits Online, register for an account

    The person who will submit the application should register for the account.  You can access Permits Online from TTB.gov in the “Doing Business Online” section or click here to access the Permits Online log in page and select “New Users: Register for an Account.”

Key points:

  • Once you submit the account registration form, you’ll receive an email to verify your account information.  IMPORTANT – you must click on the link in the email to activate your account.
  1. Gather the documentation you’ll need to submit

Before starting your application, you should gather the supporting documentation that you’ll be required to upload in Permits Online with your application package.  See What to Gather before You Apply for a list of the documents you’ll need.

  1. Determine how many Personnel Questionnaires are needed and how they’ll be submitted

The Personnel Questionnaire is how TTB gathers necessary background information about owners, officers, and others associated with TTB-regulated businesses.  We recommend that you review this information before you start the application process to see if you’ll need to submit any Personnel Questionnaires, and if so, how they’ll be submitted.

Key points:

  • Because a change in proprietorship means that there has been a change in the person or entity that owns the business, we may need Personnel Questionnaires in order to process the permit application (see People and Positions that must be covered by a Personnel Questionnaire)
  • Personnel Questionnaires may be completed and submitted through Permits Online either by the person named on the Personnel Questionnaire, or by the person completing the permit application (on behalf of the person named on the Personnel Questionnaire) (see Options for submitting Personnel Questionnaires).
  • In some instances, we already have Personnel Questionnaires on file for certain people associated with the business.  If they were filed in Permits Online you can view them on your My Submissions page.  We need a new Personnel Questionnaire for these individuals if the person’s name or criminal history has changed since the personnel questionnaire was originally filed. 

Submitting your Application through Permits Online

Follow these steps to use Permits Online to submit your application and request to be accepted into this Temporary Voluntary Disclosure Program.  Click the boxes to view detailed instructions:

    1. Log into Permits Online and select “Apply for new permits, registrations, or notices”

      Once you have a Permits Online account, use this link to Log into Permits Online .  You can also find a link to Permits Online from the home page of TTB.gov in the “Doing Business Online” section.

      Select the option for “Apply for new permits, registrations or notices.”

  1. Complete the New Applications Wizard 

The New Application Wizard walks you through a series of questions to determine what applications you will need to submit.

Key points:

  • In Step 1 of the wizard under Commodity Selection, you’ll see instructions that indicate you may apply for multiple types of operations (for example, wholesaler and winery) at the same time.  Please ignore that information.  Industry members are only eligible for this Temporary Voluntary Disclosure Program if they are solely engaged in business as alcohol wholesalers or importers.
  • The exception is, if you will be operating as both a wholesaler and importer at the same premises location under the same EIN, and you failed to timely report a change in proprietorship for both permits, you may apply for both operations at the same time.


    • In Step 1 under ENTITY INFORMATION, please answer “No” to the question “Do you currently have another permit with TTB under this EIN?”
    • Select from the dropdown how you will submit Personnel Questionnaires for the owners, officers and others required to complete one.  For additional information see Options for submitting Personnel Questionnaires.

  • Step 3 will display your custom Application Package.  Everyone will have an Application for Original Entity, and based on how you answered the questions in Step 1 of the wizard, you’ll also have an Application for Alcohol Wholesaler/Exporter and/or an Application for Alcohol Importer.  You may also have one or more Personnel Questionnaires in your application package, again, depending on how you responded in Step 1.

    Select “Start” to complete each form in your application package.  You’ll only be able to submit the application package after you’ve completed all the forms.

    1. Complete each application in your application package

      Application for Original Entity

      This application will establish the Permits Online entity record for your business based on your Employer Identification Number (EIN).  All of the information specific to your business entity is contained in the entity record: business name, EIN, ownership information, officers, powers of attorney, signing authorities, and trade names.

      Key points:
      • In Step 3b, you’ll be required to upload certain documents in support of your application, as well as the signed, written Request and Certification statement on company letterhead, which is required in order to participate in this Temporary Voluntary Disclosure Program.  A sample statement is provided in Attachment A.  Under Type, select “Voluntary Disclosure Request.”

      You might find it helpful to preview the Application for Original Entity.

      Application for Alcohol Wholesaler/Exporter OR Application for Alcohol Importer

      This application will establish your operations, in this case either as an Alcohol Wholesaler or Importer.

      Key points:

      • In Step 2a, please check the box for “Change of proprietorship-ownership.”

  1. Submit your application package

    Once you’ve completed all the applications in your application package, select “Submit Application Package.”  You’ll receive email notifications if we need additional information from you and when the status of the application changes.

Once you receive notification that your application has been approved, you may log in to Permits Online to view and print your new permit, as well as other approval documents.

Additional Resources

To learn more about Permits Online and the application process check out the Permits Online Tutorial and the Permits Online Help Center.


Back to Industry Circular 2019-2



Page last reviewed: July 7, 2019
Page last updated: July 7, 2019
Maintained by: Regulations and Rulings Division

Last updated: January 21, 2020