Enhancing Office Enforcement: top 10 tips and tools

1. Enhancing Office Enforcement:top 10 tips and tools Presented by Trent Knoles Illinois Department of Revenue September 24, 2010 Mesa, AZ

2. Two areas of IFTA enforcement • Roadside Enforcement

3. Two areas of IFTA enforcement • Office Enforcement

4. Basic Assumption: The most-effective roadside enforcement begins with effective office enforcement.

5. What is “office enforcement”? • Reduce the number of potential risks from the onset • Eliminate the proven risks

6. Three Areas of Concentration • Educating your population • Scrutinizing your application process • Keeping your population in compliance

7. Top 10 Tips to Improve Your IFTA Office Enforcement

8. Tip 1 Educate your carriers. Do they know if they meet the requirements of IFTA? - Have a good web site - Have a good Carrier Compliance Manual - Send brochures to truck driving schools - Place posters in scale houses - Have a booth at fairs - Have a booth at trucking conventions

9. Tip 2 Go beyond the Agreement’s requirements for your IFTA application – require as many identifying numbers as possible. - Your state’s business tax number F - FEIN (or SSN) of the company - SSN of all owners/officers - USDOT Number (Verify with SAFER) - IRP Firm Number

12. Tip 3 Cross-reference those numbers for possible “hits”. • If those numbers match between the owners/officers of a revoked company with a new in-coming company, DO NOT issue a license without clearing up the old account first AND posting a bond. • Verify numbers with the IFTA Clearinghouse • check for previous revocations in other jurisdictions • check for current registration in other jurisdictions

13. Tip 4 Follow up with your P160 Certification Applicant agrees to comply with tax reporting, payment, recordkeeping, and license display requirements as specified in the International Fuel Tax Agreement. The applicant further agrees that base jurisdiction may withhold any refunds due if applicant is delinquent on payment of fuel taxes due any member jurisdiction. Failure to comply with these provisions shall be grounds for revocation of license in all member jurisdictions; and a statement to the effect that the applicant certifies with his or her signature or electronic submission as deemed acceptable by the base jurisdiction that, to the best of his or her knowledge, the information is true, accurate, and complete and any falsification subjects him or her to appropriate civil and/or criminal sanction of the base jurisdiction. (e.g., perjury)

14. Tip 5 Analyze your carriers’ operations. • How many trucks does he have vs. how many decals did he purchase? • Is he reporting the fuel on his returns that he indicated he used when he applied for his license? • Was he reporting 800,000 miles and now only reporting 50,000 miles? • (or vice versa without ordering additional decals) • Are his reported jurisdictions contiguous?

15. Tip 6 Use your decal serial numbers. * • Decal serial numbers designate specific decals to specific licensees. • It curtails companies from ordering additional decals only to sell them on the black market. * Decal numbers became mandatory in 2007.

16. Tip 8 Mail credentials to physical addresses only. • A physical address evokes “permanency” in a company; it gives your Enforcement Officers/Auditors somewhere to go with actual people to interview if needed. • PO Boxes (or suites) can be a “shell” address for someone simply filing false returns for the sake of getting refunds.

17. Tip 7 Do not allow Permit Agents to issue credentials. • Permit Agents do not have the tools to deny applications based on previous revocations or current tax liabilities. • Permit Agents may be tempted to sell decals at an inflated rate or on the black market.

18. Tip 9 Do not perpetuate bad compliance! • Consider certified funds for check bouncers • Bond when necessary • Revoke when necessary • Make referrals to Audits or Investigations

19. Tip 10 Use certified mail to send revocation notices. • This takes away the argument “I never received any notices – no one ever told me I was revoked”.

20. Tip 10 10 Communicate! • Maintain strong working relationships with your internal department(s): • - Bonding • - Legal • - Hearings • - Audit • - Enforcement

21. Tip 10 con’t 10 Communicate! • Maintain strong working relationships with • - your jurisdiction’s other trucking agencies • - your jurisdiction’s trucking associations • - the IFTA community

22. Tip 10 con’t 10 Communicate! • Keep the Clearinghouse up-to-date • Provide your Enforcement Officers with up-to-date-information at road-side

23. Tool Time

24. Use the tools available to you • IFTA Clearinghouse – Demographics

25. Use the tools available to you • NLETS • CVISN/CVIEW • Enforcement reports from other jurisdictions • Ride-Along • Enforcement reports from other jurisdictions

26. Use the tools available to youcon’t • Google • Review the carrier’s web site • Street View • Reverse phone number look-up • Media • Instincts • Keep attending these types of conferences! • Apply for federal grants • Pass legislation for funding your administration and enforcement of your IFTA program

27. Questions?

28. IFTA Decal Placement Guide • Available for downloading from the IFTA, Inc web site. • Customizable for your jurisdiction.

29. Questions?

30. P100 LICENSE APPLICATION CONTENT The application for an IFTA fuel tax license shall be in a uniform format and shall contain, but not be limited to, the following information: • P105 The account identification number specified in IFTA Procedures Manual Section P200; • P110 Name of owner, partners or corporation; • P115 Legal business name (if different from the name given above); • P120 Physical location of the business; • P125 Mailing address of the business; • *P130 Signature or electronic submission compliant with R940.400 and P160 and date; • P135 Number of IFTA decals required by licensee; • P140 Application fee (if applicable); • P145 Decal fee (if applicable); • P155 Statement of existence of bulk storage in all member jurisdictions; • P160 Certification