No transaction report is required for internal company transfers as all RINs are owned at the corporate level. The company would submit a RIN generation report for the RINs it generated for the imported renewable fuel and a compliance demonstration report to demonstrate compliance with its RVO. The company would also submit a quarterly gallon-RIN activity report.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)