Duty Drawback in the Age of China Tariffs

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In this episode of Simply Trade, we dive deep into the world of duty drawback with industry expert Tony Nogueras. As China tariffs continue to impact global trade, understanding advanced duty drawback strategies has never been more crucial for importers and exporters.

Main Points/Takeaways:

1. Recent changes in China tariffs and their impact on international trade
2. The modernized drawback regulatory structure and its game-changing effects
3. HTS-level substitution and its advantages for various industries
4. Strategies for maximizing duty drawback recovery, including value matching
5. The interplay between Foreign Trade Zones and duty drawback programs
6. Potential legislative changes that could further benefit drawback claimants

SHOW REFERENCES
  • Tony Nogueras

Host: Andy Shiles

Host/Producer: Lalo Solorzano

Co-Producer: Mara Marquez

Machine Automated Transcript:

Folks, we’re in for another show of simply trade podcast, and it is going to be a good show today, because we’re going to get to talk about some things that are be a bit more on the advanced side of things. There’s been some recent news in the being published, talking about the China tariffs and few other things. We know it’s an election year. We know different things are going on. You know what? Different economic struggles and whatnot. We’re going to get into a topic today. We’re getting the privilege again to interview Tony nagarris. I would just say, folks, this is one that, if you’re looking at drawback services, and this is not an ad or anything like that, but I would say You at least need to check out Alliance and with what they’re offering. And whenever they’ve got a great group of people, they know their stuff, and anyway, worth checking out. We’re going to get to talk today about the new announcements. I guess there’s been a lot of things hitting LinkedIn and and different programs and different podcasts, different webinars on the recent announcement about the 301 tariffs.

Well, that that we just covered, and it’s a it’s a bit interesting how this has evolved under the Biden administration, because there was talk initially that that maybe there would be more food just granted. You know, we want to try to maybe thought in the trade war with China, talk of potentially rolling it back. And this is early in the Biden administration, and I know there were some proverbial tribal balloons that were floated, and there was such pushback, you know, obviously from from the likely quarters, union labor, but pretty much across both sides of the aisle. We don’t have a lot of bipartisanship these days, but there was really pushback from both sides of the aisle to keep those tariffs in place. And that’s essentially what happened. And ironically, now the Biden administration has gone a bit 180 and it’s looking to, well, they are not looking through. They already announced it that there’s going to be an increase in CRS on certain categories, good, you know, more strategic goods, so to speak, areas that we want to make sure that we maintained a certain amount of UK dependence, and making sure that we have a competitive and balanced police view. So that’s, that’s the latest, now certain punitive tariffs, comparing 232 which are on seal of aluminum, to get three at one, two to 32 tariffs are not drawback eligible. Really has to be challenged at this point in court. There’s maybe an avenue to challenge the drawback eligibility of those tariffs. But three at one tariffs has been drawback eligible since their initial implementation. And that’s where those folks that are in the tariff mitigation business, be it Foreign Trade Zone operators funded warehouses. This is our proverbial 15 minutes theme that they go out now for five years. As I like to say, we’ve gone from from the basement support right when you’re when your average duty rate was somewhere between,

you know, the United States, for the most part, is very open market. We have nimble barriers trade, along with most of the Dolph were both and so you’re looking at duty rates somewhere on average, between two and 5% that’s significant and and certainly drawback was front and center depending on the industry. You know, obviously in those industries where you have higher rates of duty, but, you know, throwing 25% tariffs on 500 billion in import with our with our primary trading partner on the export site equation, that sent folks scrambling for ways to mitigate terrorists out with boardrooms. And you know, once again, we sort of rocked our status and stuff. And you know, you mentioned we wanted to sort of cover some of the more advanced topics as relates to drawbacks and terrorist mitigation strategies. And, you know, obviously, companies have a variety of options to choose from. You know, altering your supply chain so that you’re sourcing from places other than China, moving operations, manufacturing operations back to United States. Then that doesn’t, you know, companies can’t turn on a dime that comes to adjusting lysine. So, you know, companies obviously are taking very hard look at tariff mitigation strategies. Each one has its own comparative advantages and disadvantages, and that’s where a company just needs to assess all the take a hard look at glycine and determine which of those tariff mitigations. Strategy appropriate. And in some cases, you layer this. In some cases, you know, a lot of our clients are operating for and create them into the appropriate simultaneously. Each one of those provides them on, I think, advantages over the other. And so it’s important to really understand some of those impossible dynamics. If I can sort of continue with that line of thought. Andy, I think there’s, there’s one area typically, where the modernized drawbacks of these provides a significant advantage over other strategies

in going there. I know where you’re going with this, and I would love it. This is one of the things. Let me stop for a second, folks, if you’re in the compliance area, this is a show that you need to, like I said, make sure that you inform those above you in that the opportunity here for the bottom line, this comes into some strategic plannings and thinking there’s some general assumptions. Hey, I just got to move away from China, or I’ve got to look at other sources, which is fine. There’s other factors that come into play as far as your source, because one of the other things is port congestion. If there’s problems in that, you still have to get your goods in. But on the other side of the coin, if everything’s flowing, there’s some things here that, from a cash flow perspective, and your bottom line that Tony, I think what you’re going to hit on is something that they need to be aware of.

Yeah, yeah, exactly. You know, I mentioned for trade, though, in many cases, companies are looking at comparing and contrasting the various tariff mitigation strategies. When it comes to zone historically, if a company had an inverted tariff benefit, right, then that’s an advantage over duty drawback. So if you’re manufacturing an automobile in a zone, and then you enter into Congress in the United States and it’s free of duty, then all of your tariffs just went away. Nobody can compete with that. Similarly, under the new to see a drawback regime. So this is what we call modernized drawback regulatory, statutory regulatory structure, which is fully implemented in 2018 this was a game changer, okay, in the world of drawback in that we significantly liberalized the substitution provision of the duty drawback statute. What substitution? Well, you know, drawback involves the import and re export material, and when you re export out of the United States, you get a refund the duties. Eric B, in some cases, we’re talking duties. We’re diving alcohol, tobacco, and in replying, petroleum products, we’re talking excise that, all of which are eligible via the drawback program, assuming they’re paid at time spent. Okay, well, under the old regime. Let’s use a simple example here. If we’re exporting a pair of Ray Ban sunglasses, and this is prior to the AP our method of matching under the substitution provision, we wouldn’t have to go back through inventory and find the exact same pair of sunglasses on the import side of the equation. We could select any pair of raygan, 123, that was within three years of the export date. They just picked that one to file.

Drawback, yes, okay, pretty simple concept. Part Number level matching, if we were exporting orange juice and we exported four to orange juice and we imported resilience. I’m talking about under the old rule, we have to make sure that they met the same specific age. We can still substitute, if we just had a more granular level, it had to be Grade A for Grade A, if you’re talking electronic component, part number for part number. So let’s fast forward the movie under the current regime. Now we can disregard grade specification and even arc number. All of that falls by the wayside, and we can match import and export at the eighth digit of the harmonized carrot number. Pretty simple concept. So now but the devil’s into detail,

so now and to that point right there you says, So in again, for those that may not be necessarily up to speed on the minutia on this, I would say that this is one of those. Basically, in general, is that you can import product from a country and you have and you’re exporting, you’re selling similar product. It’s under the same classification. Doesn’t have to be the same part number, and you can substitute that basically. So it widens the eligibility. Money of what you can claim in a duty drawback is that pretty safe nutshell,

the 100% you knocked it out of the park there. And I think,

I think a really good example recently was with Volvo importing Chinese electric cars under the Volvo brand and and exporting the very similar SUV out to Europe, but it was not electric, and that’s how they’re getting away with not having to pay duties for electric vehicles coming in from China. I believe I saw that where we talked about that in the past. Yeah,

yeah. Let me just clarify this point. Conceptually, you’re correct well, but without seeing the detail, remember, the classification has to be the same. We have an internal combustion engine that’s going to be a different HDF. So what’s happening is, you know, it’s a common business model for the automobile manufacturer. They make a particular model of an eV, let’s say somewhere in BMW in South Carolina. Everybody knows completing that plants in Alabama and so forth. These companies are importing certain models that are being manufactured in Germany or paying at that. They import domestic sale in the United States. They make different EV models in their domestic plants in the US, and they export those, and they supply those EV models from the United States following the same eight digit classification, and that’s how they’re able to do so I just want to make that point even mine. It’s got to be ACS to HCF at the but here’s where it gets interesting, and here’s where I like to refer HDF to, the HCF substitution at least 800 degree compliance. Let’s take you have an electronic distribution company, and we work with quite a few. These are large, billion dollar organizations that are importing from a variety of different origination points. Of course, they’re in for let’s take a semiconductor company. They’re importing from their plants in Japan. And what is the regular rate of duty on semiconductors? It’s zero. Okay. They have plants, let’s say in Indonesia or Malaysia. They also have plants in China. Now, all of these semiconductors or integrated circuits have different heart numbers because they have different applications. Some of the applications are in automotive they’re in household appliances across the board, in various technology applications. All of these ICs share, or portion of them share the same ACs. So you’re importing the with recap, you’re importing from Japan duty free. You’re importing from laying your duty free, and then you’re importing from China at a 25% rate of duty. Okay, all of these goods into your inventory and your distribution facility in the United States, you undergo some repackaging operations, but you’re essentially exporting the IC in the same

data. These are electronic distributors, some of the ICS that are being exported from the United States originated in where, Japan, Malaysia, there’s no duty associated with them. They are free of duty. You can use those exports of Duty Free or even domestic. So let’s say that you had a domestic US plan producing integrated circuits. They share the same ACS in that which you’re importing from China, all of the export volume that leaves the United States can be used to offset the China tariffs. So if you are sourcing from multiple locations, and you are, let’s, let’s, let’s say Export rich of that ACS from the US, because you’re exporting duty free, you’re exporting domestic you may be able to offset 100% of China’s bureau that you’re paying. The other tariff mitigation strategies, whether it’s a Foreign Trade Zone or bonded warehouse, cannot offer that type of advantage, because when you enter goods into the United States from Foreign Trade Zone for domestic consumption. You’re paying the duty, right? You’re just deferring the duty, but you’re going to have to pay it when you’ve entered goods into the commerce the United States. So really, you’re only saving in a Foreign Trade Zone. In the scenario that I just outlined, as you import from China, you’re deferring the duty, and then you export goods from China, right? And you never pay the duty. Under the drawback scenario, you’re exporting goods that originated in Indonesia and Japan, and you’re using those export items to offset the entirety of your china. A Tara, even for those ICS that you’re selling in the United States. So for certain, yes, for these electronic distributors, we’re offset 100% of their China’s era. That’s a distinct strategic advantage. Now, if you’re just importing from China, and you just react for it, that scenario doesn’t plot

Well, and that’s where I and to that point, let me jump in here is that, again, we’re getting into a few things here that can get a little confusing, folks, the the objective here, what you need to be looking at is picking out there are some things here that you have an opportunity to improve your bottom line and with your current supply chains and what’s going on, but you need an expert in there. This is where folks like you know, you know Tony’s company, and there’s several other companies out there that do duty drawback, get an expert, get them in to come in and sit down and talk with you to see if you have the opportunity, if you are a drawback eligible, and see how that that can you can incorporate these processes into your supply chain, if you will, and your accounting processes and inventory processes, because that’s one of the things right there, that if you’re going to do something, you know, check it out, and you can go from there. So Tony with that. I guess this is one of those where what I love hearing is that you’re importing from multiple locations paying those duties. There’s some of them. Obviously you said that you have some that are on the China tariffs that basically it’s like bringing in some goods out of China as one of your sources. You have the extra 25% duty on it with the three Oh ones. But you’re selling, and you could be exporting, let’s say, goods that are manufactured in Brazil, if it was the same HTS, you’re able to do a duty drawback off of the Chinese goods and keep going. And you, yeah, so that’s that, right? There is, like, whatever item, I guess, that has the highest duty rate. When you’re exporting, you’re able to substitute that in in claim that. So that’s, that’s the beauty of that,

correct? Yeah, let’s say I’m importing IC from Germany, or some other product from Germany. Let’s say that this at the regular rate of duty of 3% but I also have different Park number same HTS from China at 25% so anytime you make an importation at 30 days, it’s like making a deposit into your drawback bank account, okay, in order to make a withdrawal, you need to have merchandise that shares the same ACs. It doesn’t matter the source where that export originated from. Doesn’t matter. All that matters would share the same API, the point that you just made, Andy, which, which would, which was the various points, and that is, well, what if I have imports in my bank, some of which that are doable at three or 5% and others that are dutiable at 25% they share the same ACS under the substitution provision, we want to exhaust the 25% import service. So we’re going to chew those up

on a high to low basis. And so the overall point here is that in order to maximize the program, you really need to dive deep into the analytics side of the equation. I haven’t even ventured into some of the other rule, making that even places that higher premium on advanced type of analytics. I’ll give you one example of that. So here are some of the tripping points. And you said you wanted advanced topic. Well, for better or worse, you know, at the risk of speaking Greek and losing our audience here, I’m going to wade into some of the nuances now. HDF level substitution, what a great concept. There are some members of Congress that said, Well, wait a second. Here we have HCSS that are very broad, that are catch all baskets, basket provisions that begin with the term ugger at the eight digit doesn’t have a specific product description, right? And there was some concern in Congress that it was, it was printed too much of an advantage, or giving away the sword sign. We want to make sure at least similar merchandise is being exported. And so consequently, there was a last minute compromise. And the compromise essentially was okay, if your classification falls into this catch all basket, other at the eight digit, then you got to jump to the 10th digit. And if we have a statistical breakout at the 10th digit, you can still claim. Under the substitution provision. And by the way, this only applies to what we call past three drawback there’s a manufacturing drawback that’s a different category where you’re importing raw material you make into a different article of commerce, and you export the finished product. What we’re talking about here is you import and export at the same level of production and that. And so the compromise was, it’s a 10th digit. You can claim HDS level, Substituting, we all know we have classifications that never get to a stat breakout. There are other other. So what happens there? If you’re other other, then you cannot file under HDF level substitution, your alternative is to go back to the part number level matching and file under what we call j1 or direct identification drawback, which has a much higher compliance bar. And so unfortunately, there was a proverbial list of winners and losers that came out of this. That story change in 2018 and if you’re on many of your classifications begin with other or other other. FDA consent, your only alternative now is 500 Correct. I can I just drawback. So this was, there were quite a few companies that fell into that trap. And so this hdsl substitution was not a net positive. I mean, it wasn’t that positive for sure, specific company. It was a net negative. Right now, here’s the good news. We’re trying to clean that up with a statutory change. All right, so we’re going back to we moved the ball to the red zone, as we like to say, it’s football. So it was a net positive for the industry. Eight debt level substitution at the eighth wonder of the trade compliance world, as I say, but we didn’t cross the finish line for everyone, or the goal line for everyone. So the industry, a coalition of members of the industry, got together. We got committee so forth. This process would be driven in Washington, DC, their current lobbying efforts in place that will essentially remove this restriction, so that now even classifications that begin with other at the will be brought back eligible under the substitution Now we all know it’s what we like to call Philly season in Washington, DC for an election year. Yeah, and those waters were just muddied a bit by we won’t get into politics here, but we all understand the dynamic that what happened recently out of New York, and so there’s even less cooperation, if that was even possible on bipartisan measures. So we’re probably in a bit of a standstill even when it comes to bipartisan trade legislation. I know there’s what it says, because the question is, is there a legislative vehicle between now and November, whether it’s renewal GSP or other potential vehicles where we can attach this particular technical change to that would really create probably hundreds of millions of millions of dollars in additional refund to the trade community we shall see probably our first shot, I’m guessing. You know, in many, in many instances, they have the proverbial lame duck session of Congress, which is subsequent to the November election and prior to the swearing in of the new Congress, and in many instances, they’re a huge push to, you know, move legislation through this that has been sitting on the sidelines as as we waited for the election result. So maybe during lame duck session, we’re all cautiously optimistic

with that, let me ask this question. Is that of the different opportunities here, Tony, do you have some examples of what some companies have been able to do, as far as their recouping? I mean real you

examples of what some companies have been able to do, as far as their recouping? I mean real you

obviously have some great customers, but some examples of they went through the efforts of getting set up to do drawback, which is not something you just flip a switch and do you’ve got to do certain setups and get ready for it in accounting things and reports and all that. But to that point, what’s been the results of it for some of these companies that you’ve seen.

Okay, well, let me so now we’re building in a bit of the process. And let me just say that with any company that approaches them and wants to sort of assess and evaluate this opportunity. Be and whether it’s viable, because, as we like to say, the proverbial juice has to be worth wheat, right? It’s not. It’s not that you necessarily have to set up additional processes and procedures. In most instances, a company of existing record retention should be able to support its drawback fleet. Now, when we’re talking 25% tariffs, what we’ve seen out there, you know, when the average tariff rate was between two and 5% in most instances, the tail is not going to wag the golf right? The company’s not going to alter supply chain in order to maximize drawback recovery. But now you’re talking about the regular rate of duty plus with 25% so we’ve seen companies, in certain instances, alter their supply chain, in their logistics models and their business models in order to maximize recovery. It’s that impactful. And I’ll give you an example here, one of the big winners. I talked about proverbial list of winners and losers. Anytime you have a statutory change, right? It was considered, you know, among industry experts and insiders, you try to assess and evaluate that list of proverbial winners are for us? Why? Because we want to target them to potentially potential account, and number one on the winners was going to be the alcohol industry. Well, why is that ACS level substitution under the old rule, if you were exporting list based vodka that you imported, Smirnoff that you imported from your manufacturing facilities in Europe, and you exported to Latin America, then you could claim Smirnoff, or Smirnoff, it had to be specific, essentially, to the brand, right? No longer the case with HDF double substitution.

So with that you can, you could have, like domestic produced vodka and still import your Smirnoff, if you will, correct and ex, and then sell your domestic vodka, but still do a duty drawback on the the Russian, or, well, I say Russian, whatever, Smirnoff is now manufactured from,

correct? So, yeah, for example, let’s say that Diageo, or brown informant, went out and purchased keto and Ketos is exported all over the world. So all of a sudden they’re export rich, right? And they’re importing the rock, which is produced in France, from grapes. And I’m sure there’s substantial because it’s a very popular high end vodka. There’s only one classification for vodka. There’s a slight difference as it relates to the volume, but for the most part, if you’re in part, would be not volume, but value in this boat there. But for the most part, there’s one classification for vodka. So what does that mean all imports of body in the United States, you’re paying XYZ kind of importation. If you have offsetting exports, even if they were produced in the United States as a ketosis, you can use that authentic the excise tax associated with this rock that you’re seeing at the time of entry. Okay? Is huge, huge. Let’s give another example, mostly cooler right now. I’m not speaking out of turn here. We have non disclosure agreement with all our clients. These are not life clients, but I know they’re business models, okay, but importing molten from Canada pay your excise tax at the time of importation, and now you have the miller lite that you’re distributing from the United States to the Caribbean. Well, because the miller lite stopped being consumed in the United States, there’s no excise tax that you have to pay. That’s essentially a thin tax, right? So if you’re exporting, the miller lite never paid the excise tax. So that’s considered customs consider that to be having your cake and eating it too. Or, quote, double drawback. So and in fact, you know, anytime the law change,

customs, gets the opportunity to rewrite the regulation. Sometimes we do collaborative effort, but their word is law in the universe, until you do what, taking the court or go back to Congress to change the law. So we know that Congress grants customs broad deference to administer these programs right and customs when they publish the regulations, they finally did so the math on this, and there were people on Treasury that were not all too key when they discovered this. This was not going to be revenue neutral, that the alcohol industry was going to be able to bypass one of those excise taxes. And so guess what? They included a regulatory provision that said, By the way, if it’s regular duty, there’s nothing we can do about that. We think there should be a special rule not excise tax. And so we’re going to say that that’s not eligible energy. So they tried to undermine the alcohol industry, the big winners. And so you know, a lot of these, more you know that don’t be some of these more controversial points that don’t rise the level of importance, once again, the juice not worth wheat. Then customs can say no for many years, because there’s just not enough money in to litigate. But when you’re talking excise tax in the alcohol industry, oh, they were slapped with with litigation almost on day one, and and they lost badly the court of international trade. So that badly won, or customs has unlimited. The government has unloaded resources, and they feel they lost on appeal,
as well

any other industries in particular that have really benefited in the electronics, a big one,

electronics, as I because they’re all sourcing from multiple origination points. So HDF global substitution was real willing to that, but even, but even in situations where maybe a company is just importing from China, and flexibility associated with HDF level substitution really lowered the compliance part of it, but it did introduce about a little making. And let’s go back to the example of the sunglasses. So if you’re exporting Ray Ban 123, under the old regime, you have to match against an imported beer. Ray Ban. Now you can export Ray Ban 123, and match against an imported beer vocally. Why? Because they share the same classification at the eighth digit. But what about if we go down, you know, the type of sunglasses Andy that you probably wear these pickup down in the wetland? Sorry, that was media call there. That was a gratuitous shot there at your fashion set. But let’s say that you’re importing, you know, the cheaper sunglasses that you buy down at the local 711 and we’re exporting those. What can you would they share the same? ACF? There’s such a disparity of value that can’t be right,

but the commodity is still the same. I mean, ultimately, it’s sunglasses, whether it’s a 50 cent item or a $500 set item, right, correct? But

here, for the devil in the detail, it’s a lesser of two values that you get drawback on. Okay, so if you export the pair of sunglasses that has a wholesale value of $5 and you’re importing the Ray Bans that have a wholesale value of $30 and 3.2% or actually, I think 2.1 or 2.3% is the actual rate of beauty. You only get the lesser of the two. So consequently, what does that mean when you’re constructing your drawback plan? What that means is you better pay close attention to your value matching. If you’re export rich, you don’t want to match a low value export with a high value import, because you’re going to leave money on the table. And so we’ve seen with existing drawback programs. That means, Eric, the first thing we do is conduct a detailed assessment, right? And we’re going to look back in time, because drawback has a retroactive future. You have five years of disagree that’s

unstable. You have five years of native import to file a drawback plan. So if you’re a new program, you could be sitting on a substantial windfall. That’s historical recovery. So that’s a good thing. Year one, you could be sitting on millions of dollars. That’s going to hit your bottom

line, folks, this is one of those where, if you’ve not been doing drawbacks, and you’re at a point where, because the economy has been sucking wind at different times and whatnot, you may be looking for something to help, you know, take you over the top here for a while and or whatever. As Tony just said, you may be you’re able to go back five years. You may be sitting on a gold mine. Don’t even realize that. So again, you need to get your experts in as a you know, drawback is not something that you just willy nilly look at. You’ve got to do some work on it, but it is well worth the investment that you have to put in and. Your time, your people’s time, your reports and getting that information out to investigate that with the right people, and get yourself set up to where you can start drawing back, you know, some dollars to your bottom line. Yeah.

And if I can highlight that point, so if you have an existing program, step one look under the hood of the historical recovery. We want to make sure that you maximize your recovery with proper value matching, because that’s a tripwire in this process. And we’ve discovered companies leaving millions of dollars, and you have the opportunity to go back and amend claims for supplemental piloting. You can, you can rework these claims if there was money that was left on the table. Also, we, we’ve run into companies that filed, non complied filing, okay, for example, if you’re exporting Canada, Mexico, you can’t claim that under j2 if you’re exporting to Chile thing. So some of those exports snuck into your unused substitution claim that was non compliant. So step number one, if we want to assess the path with the recovery that was left on the table, secondarily, is there any compliance exposure if you’re a new filer, then step one is, let’s try to put a number on this opportunity to make sure minimally that’s viable. How do we go about doing that? Well, if you don’t have a fact that that’s step one, we go grab some ace reporting, set you up in the ACE portal, run some very specific reports, and we will conduct an HTS level set, because you have far through your level details, so we can’t assess evaluate manufacturing drawback in a or j1 in a, because there’s not parent under level detail, but we can certainly look at the HCF level to see what matches at a very high classification level. And depending on what we see there, right out of the gate, we might have millions of dollars in potential recovery. And then the next step is, let’s move into the implementation phase. Let’s start setting up our procedures. How are we going to gather the documents and data in order to maximize program? So it’s really just project, and the project is divided into two phases. Phase number one is, let’s look at the path and maximize this, and then implement procedures so that in a go forward, we’re filing drawbacks regularly on a quarterly or monthly basis, whatever really most at the stage. So it’s an ongoing process, and with that, I will turn it back over to you. So the big takeaway is, look under the hood, conduct an assessment, even if you have an existing program, and certainly if you have potential for new program. And you know, if we run into a situation where we think the zone is really the most advantageous, strategic approach, we’re going to say, look, implemented zone, and instead of drawback, it makes the most sense because of the reason. So we’ll try to be very objective about this analysis

well, and even with if you’re implementing a zone, you know, you still have the opportunity to utilize drawback as a stepping stone to capitalize on some of the past opportunities while you’re looking at him in the zone from this point on, going forward, and again, that zone takes quite a while to get up and running. All that to say, Tony, I got to tell you, you know, we could keep going, but obviously, for

sake of time, we need to wrap up here, folks. We’re going to have Tony back to talk through about some of the basics of okay, I am You’ve piqued my interest. We’re actually now going to go back to drawback 101, and go through a little bit more of the basics of how to set this up, who to talk to, and all that. But basically, right now, if you’re in a compliance area, you need to make sure you reach out to your CFO or your Finance Directors and all that, and build an alliance there and relationship, as well as talk through this, because that’s the avenue that you need to go with to try and see all right, you need to at least invest in bringing in an expert to initially do an assessment. Are you drawback? Eligible go through those things, and secondarily to that, then it’ll be a multi divisional type thing to look at, harness that for longer term, to maximize your your efforts. So Tony, man, I just, man, I love talking with you. You just, you’re gonna forget more than I’m gonna get to learn, buddy.

Well, I appreciate that. And I like how you use the term Alliance there, that it’s an alliance. So it’s a collaborative effort to leave it on that point. And I really appreciate the opportunity to address your audience. It takes pleasure on my side of the equation as well. And you just say the word. We’d love to come back on lab and and continue the dialog with with you and Irati. So I really appreciate the opportunity.

Definitely, definitely, Lalo. We’re going to have Tony’s contact information and the information there and about the company if they’re interested in that, along with if there are any questions. Folks, can you know, send us notes, send us comments or whatever. Share this, do whatever. But we appreciate their support, because we are growing as a as a show thanks to the listenership here.

Yeah, and thank you. We will so Tony will have your contact information as well as Alliance as well, and so people should be able to scroll down and view your information. But for everybody that’s listening, you should just check our show notes and you’ll find that information on there. And

thank you, sir and with and Lalo, hope you all have a great day and look forward to the next show.

My pleasure. You.


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