**[General Correspondence for Amendment of Existing ITAR Authorizations
Due to U.S. Entity Name/Address and/or Registration Code
Changes]{.underline}**

Pursuant to §122.4, a registrant must notify the Directorate of Defense
Trade Controls (DDTC) of all material changes to their registration
file. These changes include restructuring, merger/acquisitions and/or
registration code consolidations. Per §122.4(c)(3), the licenses
affected by these changes must be identified via a list to DDTC. Any
licenses not identified on the list will be considered invalid. Per
§122.4(c)(4), affected agreements require an executed amendment for a
U.S. entity name change within 60 days of notification. Any agreements
not so amended will be considered invalid.

Historically, these changes have been made via a DSP-119 for a DSP
license or a major amendment for agreements. Amending existing
authorizations because of a name/address or registration code change can
impact a large number of licenses and involve many hours of work for
both the U.S. Government and the applicant as well third-party license
holders. Recently, DDTC has moved to utilizing General Correspondence
(GC) requests to approve and document U.S. entity name/address and
registration code changes. The GC covers approval for both DSP licenses
and agreements. This was done as a way to reduce the administrative
burden on industry and DDTC in processing such amendments.

The guidelines that follow offer a procedure to make this process more
efficient while ensuring the integrity of the historical database and
all requirements are met. The use of a GC request is applicable
regardless of the number of authorizations to be amended.

[Timing]{.underline}: The GC request should be submitted within 60 days
after the Directorate of Defense Trade Controls-Compliance (DTCC)
approval/acknowledgement of the change.

[Registrant Requesting Name/Address or Registration Code
Changes]{.underline}

The registrant notifying DDTC of the change is responsible for
submitting a GC for U.S. entity name/address and/or registration code
changes. All requests for the transfer of licenses and agreements must
include the following documentation.

1)  A GC letter

2)  §126.13 certification letter

3)  Copy of the DTCC's letter acknowledging the requested change(s), if
    issued

4)  Matrix/spreadsheet of authorizations to be transferred

The GC request must have a subject line clearly stating the GC request
is to amend export authorizations due to restructuring,
merger/acquisition and/or registration code consolidation. The request
must provide DDTC with concise description of the proposed transaction,
in particular identifying the registrant code of the acquiring company
and the registration code of the company being acquired. The request
must list the submitted documentation and specifically state if a DTCC
letter is attached.

The GC request must also include the following statement for the
amendment of agreements as a result of mergers and acquisitions. If no
executed amendment is required then this statement is not necessary:

> "Modifications to the existing agreements submitted as part of this
> letter are specifically limited to **a change to the registration code
> and/or to the U.S. entity name as a result of an approved merger or
> acquisition,** and are signed by the new U.S. entity, the former U.S.
> licensor and the foreign licensee(s). Any other modifications will be
> requested through a proposed amendment in accordance with
> **§**124.1(c) or (d)."

The spreadsheet/matrix of authorizations to be transferred must include
all existing and pending authorizations. Only those authorizations
identified in the list will be amended. Any authorization not included
will be considered invalid and a new authorization must be obtained. The
spreadsheet/matrix must include the following information for each
authorization:

1)  Type of authorization (TA, MA, DSP-5, DSP-73, etc.)

2)  License or agreement number (for agreements, the last approved
    amendment should be identified)

3)  Country/s of export

4)  Unshipped value for licenses/total value for agreements

5)  Disposition of authorization (Approved or Pending Approval)

6)  Date of Authorization Expiration

7)  State Y or N if an executed amendment is required, for agreements
    only

For ease of review, the list should be separated into existing
authorizations and pending authorizations.

Affected agreements will be annotated in DDTC's database but only those
identified on the spreadsheet will be processed. If only the
registration code is changing with no resulting name change, the GC
request is the only required action by the registrant. If the U.S.
entity's name changes, an executed amendment must be submitted to DDTC
under separate cover but the agreement must be listed in the GC request.
The executed amendments must be submitted in accordance with §124.1(d)
and cite the GC case number in the body of the cover letter. Prior
written approval by Directorate of Defense Trade Controls-Licensing
(DTCL) is required for any amendment making a substantive change.

The DDTC response for the GC will include an annotated
spreadsheet/matrix identifying any authorizations not amended. If no
annotations are provided then all requests authorizations have been
amended. Prior written approval by DTCL is required for any amendment
making a substantive change.

[Third Parties Affected by Change]{.underline}

A "third-party" is a U.S. entity other than the registrant who has
submitted the GC request. DDTC will issue a web notice acknowledging the
U.S. entity change and providing instruction on third party
authorization holders as below.

When a third party license is affected by a U.S. entity name change, a
DSP-119 will not be required to be processed for the affected DSP
license. The DDTC issued web notice will serve as approval for the
change and must be attached by the license holder to the affected
license.

When a third party agreement is affected by a U.S. entity name change,
the agreement holder will be responsible for amending their agreement.
The executed amendment will be treated as a minor amendment per
§124.1(d) and must be submitted as such. The agreement applicant of a
pending agreement/amendment request requiring change is responsible for
notifying the assigned Agreements Officers. The necessary changes will
be made prior to issuance when the Agreements Officer has been notified.