1. Get Ready for Annual Reporting
Kathryn Terry
Motiva Enterprises LLC

2. Annual
Reporting Requirements for FTZs
• What are the requirements for annual reporting?
– FTZ Board Annual Report per 15 CFR §400.46(d)
– Annual Reconciliation per 19 CFR §146 Subpart B, 146.25
– Annual System Review per 19 CFR §146 Subpart B, 146.26

3. FTZ Board Annual Report
• Submitted by the Grantee to the FTZ Board
• Technically due by January 31st of each year, however,
best to complete and submit to grantee by December 31st
each year.
– Grantees have many subzones to report on.
• Annual report is for the fiscal year so it can be completed
well before the deadline.

4. FTZ Board Annual Report
• Where do you start?
– http://ia.ita.doc.gov/Ftzpage/annual-report-guidelines.html
– Specific guidelines for Oil Refinery Subzones.
• http://ia.ita.doc.gov/Ftzpage/ftznew/oil-guidelines.html

5. FTZ Board Annual Report
• Part V: Subzone Activity
– A. Summary - items 1, 2, 3 often do not change from year
to year and can be copied from previous year’s report.
• 1. Owner and Operator: has company ownership changed?
• 2. Subzone Site and Plant Facilities
– Minor or Major Boundary Modifications
• Description of Activity
• 3a, 3b1: ICRS-generated
• 3b2. Types of Customers: if changed from previous year will
need updating.
• 3b3: ICRS-generated.
• 3b4. Types of customers for petrochemical products: if
changed from previous years udpate.

6. FTZ Board Annual Report
• A. Summary – continued
– Table to be completed with information that is not available
within the ICRS.
• 1. Percent exports
– Direct: left the refinery for immediate export.
– Indirect (if known): if finished products are sold for export and
those figures are known.
• 2. Current rated crude distillation capacity
– Report for all sites in your zone.
• 3. Employment
– Direct: employees that work for the company
– Indirect: contract employees

7. FTZ Board Annual Report
• A. Summary – continued
– Table to be completed with information that is not available
within the ICRS
• 4. Volume of total crude receipts on average daily basis.
• 5. Volume of foreign crude receipts on average daily basis.
• Estimated percentage of foreign crude receipts under 25 degrees
API.
– 4. Crude oil throughput information
• Grant of Authority
• Review yearly to be sure within limits of authority

8. FTZ Board Annual Report
• A. Summary – continued
– 5. Economic and Business Benefits
• In addition to detailed statement, annual duty savings can be
included in this section.
– 6. Benefits to Local and National Economy
– 7. Restrictions

9. FTZ Board Annual Report
• B. Movement of Merchandise
– This section takes the longest to complete.
– Some information will be populated by ICRS.
– Some information needs to be calculated.
– Preparing reports or spreadsheets to extract needed
information is what takes longest.

10. FTZ Board Annual Report
• Sources of Information for Annual Report.
– Inventory Control & Recordkeeping System
– Refinery Human Resources (employment figures)
– Tax department (tax savings for being in a zone for
economic benefit section).
– www.eia.gov for pricing information.
– http://ia.ita.doc.gov/ftzpage/ftznew/oil-guidelines.html for
instructions on preparing the Annual Report
– Export department for direct and indirect exports from the
zone.
– Marketing department (information on types of customers).

11. Crude Oct-08 Nov-08 Dec-08 Jan-09 Feb-09 Mar-09 Apr-09 May-09 Jun-09 Jul-09 Aug-09 Sep-09 Total Avg. Price
Mars $84.49 $65.95 $42.98 $37.21 $36.06 $43.37 $44.92 $50.22 $60.39 $61.58 $64.71 $66.50 $573.89 $47.82
Poseidon(used West TX Sour) $84.49 $65.95 $42.98 $37.21 $36.06 $43.37 $44.92 $50.22 $60.39 $61.58 $64.71 $66.50 $573.89 $47.82
Arab Light/Arab Med-landed $73.08 $50.90 $40.58 $39.02 $38.54 $43.05 $48.87 $52.65 $66.13 $64.30 $71.34 $66.78 $582.16 $48.51
Mondo and Hungo $72.71 $50.70 $40.42 $40.96 $42.24 $46.16 $49.05 $55.35 $68.41 $65.33 $72.21 $68.44 $599.27 $49.94
Basrah/Kirkuk/Kole $73.30 $51.46 $40.41 $41.59 $42.47 $45.28 $49.33 $55.28 $68.29 $65.70 $72.47 $68.14 $600.42 $50.04
Bonny Light/Escravos $79.90 $56.56 $45.45 $45.63 $46.72 $48.69 $51.38 $57.37 $70.28 $66.62 $74.16 $70.21 $633.07 $52.76
Forcados $80.32 $57.50 $46.31 $46.35 $47.07 $48.39 $51.02 $57.09 $69.95 $66.19 $73.26 $69.26 $632.39 $52.70
Heavy Louisiana Sweet $97.85 $72.74 $50.82 $40.00 $39.86 $45.28 $47.51 $52.43 $60.10 $65.67 $65.95 $70.26 $610.62 $50.89
Louisiana Light Sweet $78.76 $59.41 $39.93 $39.55 $38.07 $47.78 $48.78 $56.52 $66.64 $63.40 $69.59 $69.55 $599.22 $49.94
Qua Iboe $79.90 $56.56 $45.45 $45.63 $46.72 $48.69 $51.38 $57.37 $70.28 $66.62 $74.16 $70.21 $633.07 $52.76
Lokele (used Kole price from EIA) $73.26 $50.29 $38.93 $40.08 $42.34 $45.10 $47.67 $54.08 $67.18 $64.54 $72.45 $67.83 $590.49 $49.21
West Texas Intermediate $76.68 $56.47 $38.07 $36.03 $32.84 $42.12 $46.86 $54.71 $66.16 $61.45 $67.35 $65.71 $567.77 $47.31
Saharan Blend $77.01 $54.45 $43.04 $43.39 $44.68 $47.75 $50.35 $56.30 $69.09 $65.49 $72.71 $68.80 $693.06 $77.01
Cusiana Crude (API 42.6) $72.01 $56.61 $44.62 $44.19 $45.97 $50.37 $54.74 $60.42 $69.29 $67.45 $72.11 $70.42 $708.20 $59.02
Foreign Crude (API up to 30) $61.35 $48.63 $39.08 $40.72 $42.81 $49.47 $54.44 $60.03 $67.00 $66.78 $69.86 $70.18 $670.35 $55.86
Bonga (API 30) $67.11 $49.23 $39.88 $40.35 $43.00 $49.83 $54.82 $60.98 $67.06 $67.28 $70.23 $71.11 $680.88 $56.74
Natural Gas (per 1000 cft) $0.00 $0.00
Residual Fuel Oil Prices $90.97 $69.46 $50.86 $48.88 $50.56 $49.68 $49.30 $50.94 $60.48 $62.49 $68.92 $70.93 $723.47 $60.29

12. FTZ Board Annual Report
• Tips
– Start early, especially if you have multiple zones to prepare
reports for.
– If multiple personnel are preparing annual reports, ensure
consistency.
– Feel free to contact me: kathryn.terry@motivaent.com or
713-241-5948

13. Annual Reconciliation
• Per 19 CFR §146.25,
“The operator shall prepare a reconciliation report within 90
days after the end of the zone/subzone year unless the
port director authorizes an extension for reasonable
cause. The operator shall retain that annual reconciliation
report for a spot check or audit by Customs, and need not
furnish it to Customs unless requested. There is no form
specified for the preparation of the report.”

14. Annual Reconciliation
• If monthly reconciliation is being performed, no surprises
in the Annual Reconciliation.
• Run through ICRS, print to review.
– Look at last year’s ending inventory and this year’s
beginning inventory to see if they match.
• All losses/gains should have already been accounted for
during the year in the monthly reconciliation process.

15. Annual System Review
• Per 19 CFR 146.26:
“The operator shall perform an annual internal review of the
inventory control and recordkeeping system and shall
report to the port director any deficiency discovered and
corrective action taken, to ensure that the system meets
the requirements of this part.”
• How do we do that?

16. Annual System Review
• Do in conjunction with Annual Reconciliation so that it
isn’t overlooked.
• Pick one or two zone receipts
– Trace from beginning to end of the Inventory Control and
Recordkeeping System.
– Print and review relevant reports.
– Manual attribution check.
– Document findings, review any issues with software
provider.