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Storage Tank Financial Test (Self Insurance)


Form 62-731.900(3) Part A

Also Needed

General Guidance

  • Calculate FR needs, Reference Manuals, EPA link and FAQs
  • DEP Forms must be used and filled out completely
  • Verify current version of form part is used (October 2019)
  • Verify facility and tanks at site have coverage. The following should match the state registration:
    • Facility identification number (FacID) (for facilities in Florida)
    • Facility name
    • Site address
    • Number of regulated tanks (or list of tank identification numbers)
  • Confirm "owner or operator" name is same as in if not a governmental agency or sole proprietor

Financial Test Specific Guidance

  • Directions include [Insert "financial test of self insurance" and/or "guarantee"]
    • Insert "financial test of self insurance" when no guarantee [form Part B] is used
    • Insert "guarantee" when form Part B is completed and all facilities belong to subsidiary(ies)
    • Insert "financial test of self insurance and guarantee" when form Part B is completed but some facilities are owned/operated directly by the guarantor
  • Check the math!
  • The Chief Financial Officer (CFO) may have a title different from "CFO", such as Comptroller, Vice President of Finance, Treasurer, etc. but the CFO title is unlikely to include the word "assistant" - other individuals may have the authority to sign, but they will be able to produce documentation demonstrating their authorization
  • Check Independent CPA's special report when required by Alternate II line 19 (often called an Agreed Upon Procedures Report)

Alternative I

  • Lines 7 and 8 must be "YES" to pass. Confirm "YES" is accurately determined
  • Lines 9 – 12:  at least one must be “YES”  
  • See Financial Test Calculator (Excel)

Alternative II

  • Lines 8 and 9 must be “YES” to pass. Confirm the “YES” is accurately determined
  • If Line 10 is "NO" then complete Line 11.
    • When required, Line 11 must be "YES". Confirm the "YES" is accurately determined
  • Complete either Lines 12 - 15 or Lines 16 - 18
    • Lines 12 - 15
      • Check math on Line 14
      • Line 15 must be "Yes"
    • Lines 16 - 18
      •  Either a Standard & Poor's rating of BBB or better or Moody's rating of Baa or better
      • (See “Bond Ratings” below)
  • If Line 19 is answered "NO," a Special Report must be included
    • This is usually called  an "Agreed Upon Procedures Report"
    • A question occasionally asked of DEP: Does DEP agree to the procedures performed by an independent Certified Public Accountant (CPA) for the Special Report?
      • No. DEP is not a 'recipient' of the report, even though the owner or operator must show it to DEP inspectors when a financial test is the chosen financial instrument (and a special report is required). Technically, only the CPA’s client receives the report. The CPA is engaged by the owner or operator or guarantor to confirm that the numbers in the Financial Test produced by the owner or operator or guarantor are appropriately derived from the audited statements, as specified in 40 CFR 280.95(c)(5). If the Special Report claims the CPA did something different from what the federal code requires, DEP has an obligation to point out any deficiencies to the owner or operator.
  • See Financial Test Calculator (Excel)

What to Do with Completed Forms

  • An owner or operator must maintain financial responsibility records (the completed form parts with required supporting documentation) at the facility or at their business office.
  • If not kept at the facility, they shall be made available at the facility or another agreed upon location upon five business days notice by a department or county inspector.

Links to Verify Financial Statements

Links to Verify Bond Ratings

  • Moody's – Will need to set up free account, or phone Ratings Desk at (212) 553-0377. Moody’s rating must be Baa or better (e.g. Aaa, Aa, A, or Baa, but not including Baa-).
  • Standard and Poor's – Will need to set up free account, or phone Ratings Desk at (877) 772-5436. Standard and Poor’s rating must be BBB or better (e.g. AAA, AA, A, or BBB, but not including BBB-).

Legal Name of Owner/Operator or Guarantor (if registered to do business in Florida)

  •  Sunbiz - Companies doing business in the State of Florida must register with the Secretary of State.

Return to the Storage Tank Financial Assurance Forms (Mechanisms) webpage.

Form Number: 
62-761.900(3) Part A
Effective-Revision Date: 
Friday, February 7, 2020
Last Modified:
May 19, 2022 - 11:08am

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