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Perhaps the most significant mitigating control in commercial fisheries transactions is that both parties to the transaction (typically the fisher and the fish processor) are permitted entities and each has some responsibility for accurate and complete record-keeping and reporting (for example, the fisher may be required to keep a logbook showing fishing efforts and catch, while the processor is required to report fish purchased). In these transactions it is typical for the parties to the transactions to have opposite and balancing interests (for example, when a fisher is selling fish to a processor, the fisher wants the amount paid to be high, while the processor wants the amount paid to be low). These multiple sources of information and counter-balanced incentives tend to make deception more difficult to initiate and sustain. This mitigating control may not have as much effect on permitting as it does in catch reporting, but, it is still significant, because there is overlap in reporting of permit numbers, vessel and operator names, landing dates, etc. The industry understands that data collected from different sources is compared and cross-referenced.
Another mitigating control is that under the authority of the Debt Collection Improvement Act (31 U.S.C. 7701), NMFS would collect Tax Identification Number information from individuals in order to issue, renew, or transfer fishing permits or to make nonpermit registrations. Verification of name and Tax Idenfication Number will provide significant confidence that the party is who they claim to be.
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Existing permit holders may have considerable value in the system; for example, they may own fisheries quota that has significant market value. These existing permit holders must demonstrate knowledge of a secret permit access code (PAC) which was mailed by USPS mail to the permit owner's address of record. After a participant has registered and associated their permits with their username (through knowledge of one or more PACs), then the participant can access potentially sensitive permit information as well as renew or transfer permits. There are further opportunities for mitigating controls in business processes, so the e-signature process does not necessarily have to address all of the transaction risk.
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