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	<title>Comments on: New Agreement Guidelines Posted by DDTC</title>
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	<link>http://www.exportlawblog.com/archives/766</link>
	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>By: BTal</title>
		<link>http://www.exportlawblog.com/archives/766/comment-page-1#comment-97774</link>
		<dc:creator>BTal</dc:creator>
		<pubDate>Fri, 14 May 2010 16:30:20 +0000</pubDate>
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		<description>I have submitted two electronic agreements.  I like what DDTC has done as I would rather spend the extra time completing the DSP-5 vehicle rather than collate and mail 8 large sets of the agreement submission.

As long as you follow the Appendix in the agreement guidelines which tells how to complete each DSP_5 block you will be okay and should avoid an RWA.  

Approval time is much faster with the electonic submittal!  Like it or not it will be the only method of submission as of September 2010.   I think and hope that DDTC will eventually create a DSP form derived from the DSP-5 (let&#039;s say a &quot;DSP-5A&quot;) that would be specific to agreements.  DDTC seems to be making good progress.</description>
		<content:encoded><![CDATA[<p>I have submitted two electronic agreements.  I like what DDTC has done as I would rather spend the extra time completing the DSP-5 vehicle rather than collate and mail 8 large sets of the agreement submission.</p>
<p>As long as you follow the Appendix in the agreement guidelines which tells how to complete each DSP_5 block you will be okay and should avoid an RWA.  </p>
<p>Approval time is much faster with the electonic submittal!  Like it or not it will be the only method of submission as of September 2010.   I think and hope that DDTC will eventually create a DSP form derived from the DSP-5 (let&#8217;s say a &#8220;DSP-5A&#8221;) that would be specific to agreements.  DDTC seems to be making good progress.</p>
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		<title>By: LDM</title>
		<link>http://www.exportlawblog.com/archives/766/comment-page-1#comment-91784</link>
		<dc:creator>LDM</dc:creator>
		<pubDate>Wed, 14 Oct 2009 22:16:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=766#comment-91784</guid>
		<description>I dread having to use DTrade to submit a TAA or MLA.  I had a DSP-5 rejected because I spelled out &quot;Corporation&quot; in our company rather than abbreviate it as it is in our registration. They couldn&#039;t even tell me if I should put a period after the abbreviation.  What with all the extraneous paperwork involved in a TAA or MLA I see too many chances for something simple that doesn&#039;t affect the content to hold up a submission.

I hope they are prepared for the deluge of non-technical questions and frustrations.</description>
		<content:encoded><![CDATA[<p>I dread having to use DTrade to submit a TAA or MLA.  I had a DSP-5 rejected because I spelled out &#8220;Corporation&#8221; in our company rather than abbreviate it as it is in our registration. They couldn&#8217;t even tell me if I should put a period after the abbreviation.  What with all the extraneous paperwork involved in a TAA or MLA I see too many chances for something simple that doesn&#8217;t affect the content to hold up a submission.</p>
<p>I hope they are prepared for the deluge of non-technical questions and frustrations.</p>
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		<title>By: Hillbilly</title>
		<link>http://www.exportlawblog.com/archives/766/comment-page-1#comment-91782</link>
		<dc:creator>Hillbilly</dc:creator>
		<pubDate>Wed, 14 Oct 2009 17:05:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=766#comment-91782</guid>
		<description>Commerce has long licensed technology, including technical assistance (which is very much like &quot;defense services&quot;), on the same form used for hardware.  None of the boilerplate in TAAs or the transmittal letters serves any useful purpose:  Any meaningful language could all be incorporated by reference, much like some FAR clauses in DoD contracts, and any special conditions or limitations could be imposed through specific conditions or limitations for individual licenses, just like the equally arcane &quot;provisos&quot; now used.  TAAs and MLAs are not real contracts; they are simply an arcane form of license.  They persist simply because DDTC wants to be different from Commerce, and is insulated from the reality of modern business models by its splendid isolation in Foggy Bottom.</description>
		<content:encoded><![CDATA[<p>Commerce has long licensed technology, including technical assistance (which is very much like &#8220;defense services&#8221;), on the same form used for hardware.  None of the boilerplate in TAAs or the transmittal letters serves any useful purpose:  Any meaningful language could all be incorporated by reference, much like some FAR clauses in DoD contracts, and any special conditions or limitations could be imposed through specific conditions or limitations for individual licenses, just like the equally arcane &#8220;provisos&#8221; now used.  TAAs and MLAs are not real contracts; they are simply an arcane form of license.  They persist simply because DDTC wants to be different from Commerce, and is insulated from the reality of modern business models by its splendid isolation in Foggy Bottom.</p>
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		<title>By: Vito</title>
		<link>http://www.exportlawblog.com/archives/766/comment-page-1#comment-91780</link>
		<dc:creator>Vito</dc:creator>
		<pubDate>Wed, 14 Oct 2009 13:19:49 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=766#comment-91780</guid>
		<description>... and why not consider a single common DSP form for all license types that includes a check box at the top of the form to indicate which of the several DSP forms it is that we are completing? If we want to get really fancy, checking that box would grey out blocks that don&#039;t apply, but I think now I am asking too much...</description>
		<content:encoded><![CDATA[<p>&#8230; and why not consider a single common DSP form for all license types that includes a check box at the top of the form to indicate which of the several DSP forms it is that we are completing? If we want to get really fancy, checking that box would grey out blocks that don&#8217;t apply, but I think now I am asking too much&#8230;</p>
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		<title>By: C</title>
		<link>http://www.exportlawblog.com/archives/766/comment-page-1#comment-91779</link>
		<dc:creator>C</dc:creator>
		<pubDate>Wed, 14 Oct 2009 12:03:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=766#comment-91779</guid>
		<description>Clif,

I have submitted two recent Agreements using this &#039;Vehicle DSP-5&#039; method. It is cumbersome, trying to remember what information translates into which block or field on the D-Trade DSP-5 form but the return processing time has been halved!Traditionally it has taken 2-3 months for processing and our first was approved in less than 4 weeks. I&#039;m reserving judgement for now because once the floodgates open, we will see how long they take to process but right now, I&#039;m willing to deal with the confusion in exchange for speed :)</description>
		<content:encoded><![CDATA[<p>Clif,</p>
<p>I have submitted two recent Agreements using this &#8216;Vehicle DSP-5&#8242; method. It is cumbersome, trying to remember what information translates into which block or field on the D-Trade DSP-5 form but the return processing time has been halved!Traditionally it has taken 2-3 months for processing and our first was approved in less than 4 weeks. I&#8217;m reserving judgement for now because once the floodgates open, we will see how long they take to process but right now, I&#8217;m willing to deal with the confusion in exchange for speed <img src='http://www.exportlawblog.com/wp-includes/images/smilies/icon_smile.gif' alt=':)' class='wp-smiley' /> </p>
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