IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #3 - 2026

Jurisdiction Position Comments
Support: 14
Oppose: 1
Undecided: 1

CALIFORNIA		 Undecided The Jurisdiction of California is Undecided with this ballot as it is written for the submission of the proposal. California supports the intent of the ballot and agrees that submission of records for audit should be deemed as agreement to initiate the audit. However, we agree with the other jurisdictions who voiced that the language in the ballot should be revised.

ILLINOIS		 Support Illinois supports the ballot. We agree with North Carolina's language and understand the concerns brought up by Industry and Quebec.  A possible suggestion to address the comments would be :

A420 NOTIFICATION
.100 The licensee should be contacted at least 30 days prior to the conduct of an audit. Through the initial or subsequent audit contacts, the licensee must be advised of the audit period, the type of records to be audited,  the proposed audit start date, and that the audit may begin sooner than the audit start date if responsive records are received from the licensee prior to the start date.

.200      The base jurisdiction may begin the audit before the expiration of the 30-day notification period if the licensee consents, the licensee provides responsive records, or a jurisdiction finds just cause.
 
 

INDIANA		 Support

Industry Advisory Committee		 Oppose IAC would support if language were added to stipulate that the engagement notification needs to clearly indicate that the submission of records prior to date stipulated in notice will be considered start of audit.

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Support This change would remove the need for Field Audit to request that the licensee sign our 30-Day Waiver, which is currently required when records are received and the audit is initiated prior to the 30‑day notification period.

MICHIGAN		 Support

NEBRASKA		 Support Nebraska supports this ballot and has always felt that receiving the records was implied consent.  

NEVADA		 Support We support this ballot's intent, and agree with Nebraska's comment. In regard to the specific verbiage, we agree with Illinois and North Carolina's language suggestions. 

NORTH CAROLINA		 Support North Carolina generally supports this ballot but has concerns regarding the language.

The sponsor wants to remove ambiguity in A420.200. However, the phrase "may be reasonably interpreted as consent" injects its own ambiguity into the solution. In other words, instead of providing clear guidance to when an audit may begin, this language necessitates other questions to be resolved before an audit can begin. Ultimately, this would cause each member jurisdiction to determine the circumstances that would not operate as consent to begin the audit.

North Carolina suggests the following language change to A420.200 (underlines and strikethroughs are not applied):

.200      The base jurisdiction may begin the audit before the expiration of the 30-day notification period if the licensee consents, the licensee provides responsive records, or a jurisdiction finds just cause.

ONTARIO		 Support

PENNSYLVANIA		 Support

QUEBEC		 Support The jurisdiction of Quebec agrees with the ballot, which aligns with common audit practices. We would also suggest that the licencee should be specifically informed of fact that the audit can start as soon as the jurisdiction receive the required documents for the audit.  

SASKATCHEWAN		 Support The proposed amendment provides reasonable clarification to existing audit notification provisions and supports a practical interpretation of licensee cooperation during audit commencement procedures. The change does not create a new authority for jurisdictions but rather clarifies circumstances under which consent may reasonably be inferred. This aligns with existing administrative practices where licensees voluntarily provide documentation prior to the proposed audit start date. The amendment may also reduce disputes or uncertainty relating to audit timing and improve consistency between jurisdictions in the application of audit procedures.

WASHINGTON		 Support
Support: 14
Oppose: 1
Undecided: 1

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