Every party that owns assigned RINs must comply with the end-of-quarter check described in regulation Section 80.1128(b)(5). This provision ensures that RINs must be transferred with renewable fuel as renewable fuel moves through the distribution system. However, this provision applies to assigned RINs only (with a K code of 1). Any party can own any number of unassigned RINs (with a K code of 2) and unassigned RINs are not subject to any end-of-quarter check.
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
Will non-obligated parties that can hold title to RINs be required to balance them each quarter?
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