Filing with Paper Forms 720 TO/CS
If you have 25 or more reportable transactions during the month, you must file electronically. Only those persons with fewer than 25 reportable transactions may file the paper forms. Each receipt of liquid product and each disbursement of liquid product constitutes a separate transaction even if it is a single movement of fuel.
Reporting Multiple Terminals in a Single EDI File
There are three reporting options:
File all TCNs in one file;
File each TCN in a separate file; or
Submit multiple files with TCNs in groups.
The LOA you submit must specify which reporting option you choose.
Using a Single EDI file for Both the Carrier and Terminal Report
A single EDI file can be used for both the carrier and terminal report if the terminal operator and the bulk carrier are the same legal entity. Use “TOR” in the TFS02 segment for reporting as terminal operator; use “CCR” for reporting as carrier. However, with respect to transactions where the carrier and the terminal operator are the same, you must report the transaction twice: once in the terminal operator report and once in the carrier report.
Reporting Transactions When You are Both the Terminal Operator and the Carrier
Unlike version 4010, ExSTARS does not automatically generate a carrier report for you. You must report the transaction separately on the terminal operator report and also on the carrier report.
Related Companies Cannot File a Combined Report
Each entity with a different 637 Registration/EIN must have its own LOA and must file separately.