Kari Hickman, CPA
Supervisor- RIN Attestations
RIN Consulting and Attest Engagement Services
The RIN experts at C&A make it a priority to keep our clients in compliance and up-to-date on all EPA regulations and mandates.
Our knowledge of the changes in regulations from RFS1 to RFS2 will provide a smooth and easy transition for our clients.
Our experience in completing over 170 attestations will help you navigate the cumbersome regulations to ensure you are in compliance with the regulations that apply to your company.
Our work with producers, marketers, terminal operators and obligated parties allows us to have the necessary vision to understand the full complexity of RIN Reporting.
Engineering Review Update: Please contact us for additional information on the updated engineering review.
The EPA has recently released an Engineering Review Update guidance document which discusses the steps you must take to complete your update and guidance on what the engineer should be completing. Producers will be required to update registration or confirm the current registration and the guidance document describes how to complete these steps in CDX. It also discusses what is required in the updated engineer review. IMPORTANT NOTE: The guidance document notes that the EPA is planning on deactivating company registrations for any plants that DO NOT submit an engineer review update by the deadline. If you registered for RFS2 in 2010, your update deadline is January 31, 2013. If you registered after 2010, then the deadline is January 31 of the 3rd year following your registration year.
EPA Quality Assurance Program: The EPA has also recently released the beginning of a quality assurance program (QAP) which will address the RIN integrity concerns that have risen over the last two years in connection with the discovery of fraudulent RINs. A preliminary document was released discussing the program steps that would need to be taken by producers for RIN validation if the producers decide to participate in the QAP. The benefits of completing the program steps have yet to be released but it is anticipated that there will be some protection for the obligated parties if they were to buy invalid RINs from a participant of the program, which should make the participants’ RINs more marketable. A link to the EPA released QAP document is also included below. The QAP proposed regulations are expected to be released soon and to be final by June 30, 2013 with retroactive applications. Here at Christianson & Associates, PLLP we have already been working with various RIN validation programs. We would be happy to discuss our current programs with you or to assist you in setting up and/or completing your own set of RIN validation procedures.