Rule 41.22: Compliance Reporting by License and Permit Holders – To Be Recommend for Proposal

TABC General Counsel Clark Smith has advised stakeholders he will be recommending proposal of Rule 41.22 at the Commission meeting, Tuesday, September 25th.  (See agenda)

https://www.tabc.texas.gov/home/commission_meeting_agenda.asp

Smith recognizes this is an enormous shift in approach and will have an immediate impact on businesses.  He is proposing the rule not become effective until September 1, 2019, which will allow TABC to conduct voluntary pilots to test the system and iron out kinks.

Another stakeholder’s meeting is tentatively set for November 8, 2018, to discuss findings of TABC’s internal testing on the new digital application.  TABC will also share the processes involved in the self-inspection for the compliance reporting.  Smith says the questions on the self-conducted inspection will be straightforward and specific to your license/permit type.  TABC will provide further examples of those questions at the meeting.

Smith explains the goal of the project is for you the license/permit holder to perform your own compliance inspection when it’s convenient for you.  I don’t think he could have been more accurate when he says, “a policy shift of this size begs important questions that will need to be answered.”

Check back here for follow-ups as this important shift in policy continues to develop.

Let us know your opinions in the comments below.

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