EDITOR NOTE: Coin World filed a Freedom of Information Act request in June asking the United States mint to identify “the 18 dealers that comprise the controversial Authorized Bulk Purchase Program allowing the preferential purchase of select numismatic products before public release has been denied by the bureau.” The request was denied on the grounds of “trade secrets and commercial and financial information obtained from a person that is privileged or confidential.” Coin World has filed an appeal. The ABPP program allows the 18 dealers to purchase up to 10% of a mintage for a 5% premium before releasing it to the public and many want to know who these dealers are and why they get this deal. The only dealer to identify itself so far is Paradise Mint Inc.
The June 9 Freedom of Information Act request filed by Coin World seeking disclosure by the U.S. Mint of the identities of the 18 dealers that comprise the controversial Authorized Bulk Purchase Program allowing the preferential purchase of select numismatic products before public release has been denied by the bureau.
Coin World filed an appeal Sept. 14.
The citation for the Mint’s Sept. 13 denial of the FOIA request is Exemption 4 of FOIA regulations as it pertains to Title 5 of the United States Code, 552 (b)(4) protecting “trade secrets and commercial and financial information obtained from a person that is privileged or confidential.”
Only one of the 18 ABPP dealers — the Paradise Mint Inc. in East Ellijay, Georgia — granted the Mint authorization to identify its participation, information that was released to Coin World with the denial of the release of the names of the other 17 participating dealers. Coin World has been able to identify several additional ABPP participants, but unable to get the Mint to officially confirm.
The ABPP program allows participants to place orders for select numismatic products before the public on-sale date. Ten percent of the maximum mintage of those products is set aside, from which ABPP orders may be placed. The ABPP dealers pay a 5% premium over the Mint’s retail price to the public. The ABPP dealers can pick up their orders from the Mint’s contracted order fulfillment center in Memphis, Tenn.
Participant goes public
Kevin Campbell from Paradise Mint Inc., said Sept. 14 via email to Coin World that the ABPP program has proven to be a disadvantage to him.
He also questioned why the Mint did not increase mintages for certain products to meet market demand.
“The ABPP program is of very little help to the dealers that are in it.,” Campbell said. “I’m not sure what you are imagining the program is, but it supplies dealers like me with a FRACTION of the inventory I was able to order before this programs released.
“In fact I am getting less than 10 percent of the inventory I was able to buy in prior to the release of the ABPP program on just their normal dealer program.
“It is also more expensive and less profitable and definitely a lot more of a hassle to actually get the product. So if you are looking for a story that the ABPP program is some sweetheart deal for the dealers in it you are sadly mistaken.
“It is the exact opposite. There are also several omissions and product that we used to be able to buy that we can no longer get.
“A prime example is the burnished [Uncirculated] silver [American] eagle. The last four years I have ordered around 10,000 burnished silver eagles. It was wiped from the normal dealer program. It was not on the ABPP program. Therefore I got NONE. So you tell me how the ABPP program actually benefits dealers compared to the previous authorized dealer program.
“As for why any other dealers declined I can’t speak for them or their reasons.
“I would suspect they are afraid you are going to try to run some type of negative article on them like they are getting some special privileges that don’t exist.”
In a Sept. 7-dated response to a California collector, U.S. Mint Director David J. Ryder says a lot of work goes into establishing and executing each numismatic program.
“A number of important factors are considered when we establish mintage limits for Mint products,” says Ryder. “For some items, including those released through commemorative coin programs authorized by Congress, maximum mintages are established by individual public laws. Others are based carefully on marketing and demand forecasts, production costs, manufacturing capacity, and past sales history for products of similar value, designs, finishes, and price points.
“For all of our products, we strive to set mintage limits in accordance with what we determine to be the best interests of the Mint, the numismatic community, and the general public.
“As a Federal Government agency, we take our responsibility of finding the right balance between projected consumer demand and these other factors very seriously.
“Complicating all of these considerations since March 2020 has been the ongoing COVID-l9 pandemic.”
The FOIA process involves the review of requests under the advice of attorneys within the Mint’s office of chief counsel and includes cited reasons for a denial.
If part or all of the information requested is denied, an appeal can be filed within 90 days of the denial, in writing, to the appeals officer, which is the U.S. Mint director. The director will consult with the Mint’s attorneys to determine whether the denial will be upheld or the appeal granted and the information requested released.
Original post from Coin World