Expert Insights for Christmas Tariff Classifications

Andy  00:33

Hey Folks, we’re on for another show of simply trade podcast. We’re going to have a great discussion today. Folks on duty drawback, and kind of the current situation with the change of administrations and all of that. And we’re going to be talking with a friend of mine from for many years. I don’t know, Dave, Dave corn, Dave you and I go back a few years.

00:55

Yeah, we do, yeah, it’s been a little bit so my hair was

Andy  00:59

probably darker.

01:03

I had more of it. Mine was not running away from my head at that

Andy  01:08

point all that way. Yeah, it’s and, but with that, I don’t know, Lala, do you want to kind of tee up our show from your perspective? Well,

Lalo  01:18

I mean, the only thing I really want to say is I just like to encourage other listeners and the audience, if you feel or you are able, to possibly bring a topic or an episode to our show, approach us. So this is a today’s show. Is a very good example. We were in Detroit for a conference, A i A G conference, and it was a town hall, they called it, but anyway, it’s a conference. And Dave was there, and he got to talk in one of the sessions, and and he just approached us and he said, Hey, you know, I have a different angle, a different twist, to drawback that I know. I’ve heard some episodes of yours on drawback that are, you know, very standard, traditional, you know, just what everybody pretty much practices day in, day out, if you are in drawback. And he said, I think this would be really unique for your audience. And do you think you might want to have me on the shows? Like, Oh, heck yeah. You know, we we always welcome good, new, fresh content, and even if it’s not new, like drawback, a different twist to it, or different approach, a different view, perspective, etc, would be amazing. So don’t be shy. We don’t buy. In fact, we’re probably more scared of you than you are of us. You know, believe it, I believe me, I have this imposter syndrome that I really don’t feel that I should be doing this in the sense that we have this big audience. And it’s kind of strange actually, to be honest with you, but, but anyway, please do Don’t, don’t, don’t worry, and just let us know, reach out either via if you see us in person, via email, via LinkedIn, whatnot. You know, just let us know, we’ll be more than glad to to entertain your idea and work with it and bring it, bring it to the show. So but thank you, Dave, for approaching us there at the conference, and we’re really glad to have you here.

03:22

Yeah, great. Thank you guys. Glad to be here today.

Andy  03:27

All right. Well, with that, so Dave, you were talking about you’ve got a little different approach to the drawback, so once you kind of go ahead and elaborate on that, before we get too much into this?

03:40

Yeah, sure. So, you know, we’ve talked a lot about how drawback has changed. You know, a lot going on with the transition from from tifta. Now we’re going on almost 10 years since that’s gone on, but then drawback kind of transitioned to ace, you know, all of that, and some of the different pieces that we’ve had to look forward to, but something that we’ve always had, that we’ve had to work toward is, you know, we’ve had some struggles with proof of export. And you know, what are some things that folks need to do to provide extra information to make sure that they’re meeting that requirement. So for drawback, you have to have date and fact of export to show proof of exportation that something has left the commerce of the US with the intention of joining the commerce of another country, right? So, you know, what does that look like? You know, there’s a lot of different ways that folks can do that right in today’s environment, things that they want to see. But CBP will come back and ask them questions about that, and they’ll say, hey, you know, what is this document? Where is your Where does it say that you, as the exporter, are the one that has the right to claim drawback, and so if you don’t have the right information to supplement that, you’re going to have some problems in keeping that money on your drawback claim. So something that we have talked about for a couple of years in coac actually in a small. Group, we they have established a drawback task force that now has had a chance to talk through some things, but something that that export modernization working group has focused on over the last couple of years is being able to have this electronic export manifest information, some of these, these transportation elements that will be provided that will provide some benefits to folks, that will allow us to be able to cross off that proof of export requirement, so that date of exportation is populated by the carriers. It’s a real benefit for drawback, for in bond for temporary in bond movements. There’s a lot of different things that that functionality will allow that will close out some of these things that we’ve been waiting on for some time. All

Andy  05:51

right, so what you’re looking at there is, let’s, let’s talk through that a little bit. There is the carriers would be uploading their manifest is what you’re getting at. And so it would then with the bill of lighting numbers, right? Yeah,

06:06

yes. As soon as they get that information right, CBP is trying to get that information ahead of time right wherever possible. But as that date of departure can be updated after the fact, now we have our date and fact of exportation. Of course, there’s going to be different pieces to this, right? Rail and truck operate different than air and ocean, right? So we know that the manifest is going to look different, but you know that it should work the same in that that that date as it’s updated will allow us to, you know, have this requirement kind of be covered off in the system, if you will. Which should cut back on some of the questions that we’ve had on this for a number of years. This goes back even before tifta, where we had to have, you know, pedimentos in New Mexico, originally signed and stamped. And, you know, we need to, I’ve said this a lot, you know, we need to get out of that paper process for drawbacks. So, you know, it’ll be nice to to kind of see things really kind of come into the 21st century in in drawback after with such an old program. All

Andy  07:09

right, you’ve mentioned TIF t a couple times for those of our listeners on that, that’s the CBP.

07:19

Was a trade facilitation and trade enforcement, act of 2015 Okay,

Andy  07:23

thank you. My memories as long as the turtles tell so I got to get my notes going here. So anyway, so, so trade enforcement and our trade facilitation and enforcement, he said, from 2015 and so now, in today’s world, are there any new bills that are being proposed or have already gone through

07:49

for drawback? There’s a couple of things that are on the table. So a couple of things that folks are looking for when it comes to substitution. Drawback, there was a bill that was put forward this year, actually, HR, 7864 is still on the table. We’re in the lame duck session now. We’re coming up on the close of lame duck so

Andy  08:08

it’ll have to be reintroduced then next year in the

08:11

119th Congress. Yeah, so, but with a Republican Senate, you know, Senator Cassidy has released a lot of different trade legislation this year, trade enforcement and trade facilitation legislation. And so I think there’s maybe more of a chance that that goes forward next year, and some aspects of it. And so there are some drawback pieces that were released as part of that 21st century customs framework that CBP has wanted on the enforcement side, in which, of course, the trade said, hey, you know, there has to be some facilitation pieces in order for us, you know, to support this. And there are some pieces to that, for drawback that that could be beneficial. And some things that have been proposed there to minimize the burden on on privilege, applications and rulings, drawback rulings that can sometimes be a time constraint on businesses that are trying to be approved for drawback, so that can sometimes

Andy  09:11

so let me jump in here a little bit. Is on the on the scenario there wasn’t there some, because we’ve, we’ve talked to some folks on drawback. And again, I’m trying to recall, like I said, if, if I don’t have my notes, I’m like, not only in my memory short, like a turtle, still, it’s about as fast. So as I recall there was, you were talking about substitution, and now there was a scenario there where it had something to do with, like, alcohol, like,

09:46

yeah, Brown for Brown, you know, try. So there was some legislation on on whiskey to see to it that the substitution was treated the same as it is for other alcohol. So that’s something that’s on the table for this year, you know. And, and it. I think there’s a chance that that goes through in the next Congress, for sure. But also with this 7864 HR, seven, 864, legislation that would eliminate the other provision for substitution. Right now, there’s, there’s some restrictions on, you know, what they call basket or bucket categories, where an item and an eight digit HTS is classified as other, and then the description on the 10 digit line also says other. If that’s the case, then you are precluded from claiming substitution for unused merchandise. So that’s that’s an issue. So that’s something that we’ve talked about,

Andy  10:35

all right. So with that, as we’re going through and we’ll get back into your things, but just for this scenario. So you’re saying the these bills have not gone through. They’re on the table. People are talking about them. So if somebody is interested in this, in trying to enhance the current drawback rules and regulations, what would you recommend as far as people trying to provide some support in that realm, who to get involved with. Is that something like a AI or Yeah,

11:06

AEI, NCB, FAA, you know, the major trade associations are going to be connected here. Certainly coac has the attention of the legislation that’s here, and we’re discussing that as well. But if folks can go to their congressional representatives, after this has been introduced again in the 119th Congress, go to your congressional members and say, you know, can we be a co sponsor on this legislation? Well,

Andy  11:32

to that point here, here’s where I guess I want to go. Is that then listening to, if the NCB FAA, even though that’s the national customs brokers and freight forwarders Association. The thing folks, you may not be a customs broker and all that, I get that, but you can gain some information that they post on their website, and be able to gain some sort I’m looking for talking points. That’s what’s essential there, and ask questions of it, so that when you do go forward and start approaching some of the House members or senate members in your areas, you have some talking points to go through. You don’t have to make a long dissertation, just a few short bullet points. Put it out there saying you’re supportive of it, and you’re expecting their support, and if not, you want to know why that that’s that’s very important. If your representative is not supportive of these kinds of legs, this type of legislation, more specifically, this legislation, you want to know why. So it’s like so that you can make that assessment yourself. But, yeah, you

12:44

want, you want, you want some quick hits, like, like Andy was talking about just some quick hits, but then an ask, what’s the ask of the office, right? And that’s what we always say, go, go in with the ask of of, you know, we’d like you to be signed on as a co sponsor, or to have some questions for the right people that are the main sponsors, right? And, you know, we’ll be happy to follow up with you on in that regard. But if you’re not an NCB, FAA member, the American Association of exporters and importers, in the same way, you know, a lot of momentum that they’re building there. So same kind of idea for those folks that are not operating in that space, AEI is also doing a great job of trying to hit this, you know, legislation, some of the other representative you know, associations out there have heard of these things, of course, and they’re trying to build on that momentum as we go into 2025

Andy  13:29

well, and to that point, let me also just say is that when you do approach, whether it’s at the local, state or federal level, regarding gaining support for an issue that you’re putting forth out there. Don’t bloviate on who you are and all this kind of stuff and all that. Go straight to it and like what you’re trying to do. Put yourself in their shoes, if somebody is reaching out to you, you’re going to go ahead and have enough respect if I’m a representative or something, to go ahead and say, Okay, I want to listen to this or whatever, and and all that. But I have seen so often, even in public meetings and all that, and somebody will get up to the podium and they’ll go on, and I’ve done this and I’ve done that, and I’m like, What the heck are you doing? You know, just say the thing, who gives a rat’s tail? You know, it’s like, don’t, don’t boast yourself up anyway, saying all that. Alright, I’m on a little side soap box. But again, we’ll cut to the point real

Lalo  14:30

quick, just to emphasize and make that point that you just said, just to finish up on that, if you and y’all talk about ncbfa If you go to NCB FAA website, they do have a link or an option for you to help. They help you. Reach out to the representative. They’ll even write the letter or the note or you know, and they’ll do that for you. You so that you can then just copy paste. So go to that and NCB, faa.org, and go to the menu, if I can recall, it’s like they have a huge menu. They have so many services, but one of them says, contact your representative, or something like that. But just make it real easy. There, there are expert lobbyists, and they they really know. And of course, we’re not asking you to do something that you don’t want to do, you know. But if this is really something that you feel strongly about, I mean, doesn’t have to be this. I mean, I know they’re, they’re advocating for a bunch of other stuff as well, you know, like, like, like, the minimus and and what is it? GSP, you know, they want that approved again, etc. So, I mean, there’s several things, you know. But anyway, I just wanted to wrap that up, because you’re right. Andy, if you go on and on and on, they’re just not going to read that letter,

15:54

no. And it’s just about getting to the point, right? They only have so much, so much time as well. Even some of the staffers that are there, right? You know, they may be a lot younger than you, but they’ve got your you’ve got their ear for their limited amount of time, so hit it and get going.

Andy  16:10

Okay, so with that, let’s get into your points here. David’s like, as far as your approach, you’re talking about the proof of export, we’re going back on to that in that it’s going to be made easier with the manifest uploads from your carriers, right? If you’re using a freight foreigner, and they’re using, you know, so it’s a for whatever reason. Let’s say you’re you using ocean, a freight forwarder is going to have a consolidation and into a container or whatever. But you want to make sure your freight forwarder is uploading the bill of lading detail to that carrier who, in turn is turning is uploading that to custom, yeah,

16:54

you’re getting to the House bill of lading, you know, information, you know, tracking back to those transportation element so, and, you know, you had said, you know, make it easier. And that’s something that we always kind of joke about, and draw back right, kind of one of our swear words, where we throw some money in the jar, but it does, it does allow for the process to be made more straightforward. And, you know, a little bit of automation here that links the process, that links some of these parties in the chain really keeps us from having to do so much on the back end with CBP, with the follow ups that they have for us. And you know, we’re really hopeful that that keeps things moving, keeps things streamlined as we go into the future. Yeah. So that’s, that’s the goal, that’s the hope, right? And so, you know, we’re waiting right now with electronic export manifest. There are four notices of proposed rulemaking that are going to come forward, and we know through different things that CBP has said publicly that rail is the first one out of the gate. We should be seeing that one pretty soon, I would think. And you know, you’re going to have air and vessel behind that, and then truck is going to be a process that happens further down the line. Truck is a little bit more complicated given the you know, the number of individual carriers, you know the differences at the southern border versus the northern border, right? So there’s going to be some things that are being ironed out there, but we expect to see in that first notice of proposed rulemaking for rail that there will be some elements in there that will be similar across all modes of transportation that folks are really going to want to pay attention to. So I expect from that NPRM, that there will be a heavy set of comments that comes out to see if folks are on board with it, or what else needs to be done to make sure that we can get there for electronic export manifests.

Andy  18:42

Okay, so in looking at that, is there anything that somebody should be doing from your perspective? Let’s back up. I mean, there’s some positives with the manifest that’s just going to make things easier. Pardon me, with providing proof of export. But in the overall that’s, that’s just one of the elements right now this scenario is, is that you still need to have, I guess, documentation and records in your own archives, right? Yeah,

19:20

yeah. And the regulations get into that, as far as what’s actually needed, and some of those, those items, thankfully, they put in some, you know, some language with TIF Tia that says, including, but not limited to these, these documents, right? So as as E commerce becomes bigger, right, the business model is the same as a traditional brick and mortar or somebody who’s, you know, got a warehouse in Phoenix and send it from there. So it’s, you know, the documentation itself just has to look different. So in certain ways, it has to be a little bit more nimble than it is right now.

Andy  19:51

So with that, let me ask this question. Is there any restriction, or should I say. Are there any regulations regarding my record keeping for exports? Can it be hard digital, or is it have to be hard copy? Or do you have to get approval before you do anything on exports?

20:14

No. I mean, traditionally, what we do for that, I mean, we’re uploading these things into the document, image system, into D is, you know. So we’re, it’s, it’s copies of these documents that we’re sending in. So we’re not, thankfully, we’re not printing these things out anymore and sending them along to have them kind of validate that, you know, but, but you do have to keep records in drawback. You do have to keep records for quite a long time, longer than the IRS, you know, statute, you know, of limitations. So you know, if you have exports that you have from five years ago and that you’re holding on to and you’re waiting for a claim, a drawback claim to liquidate, you will have to hold on to the source of that documentation for a number of years. So you just want to make sure you may have export documentation and requirements on the export side. But then you also, if you have a drawback program, you also have to make sure that you’re following up with the liquidation standard that you need for drawback and if you tend you get rid of something, and then customs comes back and says, Hey, where’s this? This proof of export documentation that we need to finalize and liquidate your drawback claim. And you say, I got rid of it two years ago. That’s gonna be a problem. So, you know, you we need to make sure you just hold on to the source of that information. It’s not that you have to print it out, right? Keep a digital copy somewhere, but we always try to tell folks like, hey, as you have a shipment that’s leaving, keep track of keep it that all of that documentation together. Keep it all in one spot, whether you got drawback or not. And that way you you know you can easily access something that you can get a hold of if customs comes calling for it, and they will. And sometimes they really they will find the weird thing. You have a weird shipment that comes out, and you’re like, oh, this went to I never sent anything to Malaysia, and I sent this one shipment, and I had, there’s complications on the export side. I don’t know how they do it, Andy and Lala, but they do. They find the weird thing. So just make sure that you’ve got it. You know, your eyes dotted and your T’s crossed there.

Andy  22:10

Okay, anything then from there, going forward is with what you see for the future. Let’s say that these things, these new provisions, are passed in the in the legislation, in the next Congress. What? What do I do? Where’s my opportunity here? Yeah,

22:29

it depends on what goes through, right for substitution, like we talked about, if, if some of these pieces go through, it does allow more items to be claimed under substitution. Right now, if you’re restricted, then you know you have to claim on direct identification. And just by the nature of the regulations, there’s just more restrictions, naturally with having to directly identify merchandise in the drawback process. For those that need some great reading material, if you’re having problems sleeping, you know you can go to 190 14 of the regulations on that to get some alternative methods to direct ID if you can’t truly trace something, but you know, you have opportunities as well. In a retail environment, there’s a connection to that legislation that not only removes the restriction on other merchandise, but introduces new language that would allow for retail returned merchandise to be commingled with unused merchandise, and that’s something that’s, you know, is a restriction now that causes headaches. And as you’re any kind of business, right? You have returns that come back from a customer at retail or otherwise, and you’re going to bring that back in see that it’s not been used, and you’re going to put that back into new inventory like you would any other product, right? But customs, if you don’t have a way to differentiate between what is new, unused merchandise and what has been returned, customs, just looking at at that and saying, Hey, wait a minute, how do I know what in your inventory is unused merchandise? So it’s a legitimate question. So this legislation, this HR, 7864 takes out the language for other, other for substitution, and then introduces this language for retail return merchandise. So it essentially is a two for one kind of legislation. It kind of puts something in an unused merchandise that has belonged there since retail returns came into the equation, but also adjust for the other other legislation.

Andy  24:26

Okay, so what would be for somebody’s I would take it that someone that would be in your import export compliance area may be looking at this, going, okay, there may be some opportunity for our company. They, in turn, would probably need to go and, I guess, put together some kind of information packet to what their CFO or to their upper management saying. Here’s an opportunity. This is what I need to make this to go forward. So you’re going to need a few resources, I’m sure, to get some things in place and and probably even even facilitate a cross organizational meeting. But you need to get a sponsor. If you are in looking at this and saying, Hey, this is something we’re leaving money on the table, I highly recommend getting some kind of executive to sponsor you. Would you recommend that? Or what would you say from your perspective?

25:33

Yeah, I would say that for sure. I think getting to the heart of knowing what your opportunity is is kind of a great starting point, right? If you can go to your management and say, with this legislation, if this was to go through, this is going to net us x that we don’t get right now, in our drawback program, have someone be able to conduct an analysis for you, if you can’t or don’t have the tools yourself, so that you can come up with that information and say to your management team, hey, you know, Over the course of X number of years, this is what this may be able to do for us. And we need to talk to our congressional representatives and Senate members and go to them and say, here’s what we’re looking at, and here’s why it’s important to us. It does, I think it’s helpful. If you’re not the compliance person that runs the drawback program, yeah, certainly to have somebody who’s senior executive level that can get on board to support you, so that you can then take that up the chain. But you know, it helps if folks also have, you know, legislative connections. They have, some folks have teams that lobby on Capitol Hill for different legislation, and they can just say, Hey, I’m going to go to my team in Washington, DC, and I’m going to take this and and we’re going to, we’re now going to push this forward. But not everybody’s that fortunate

Andy  26:47

well, and to that point again, I guess is where I come back is in looking at it. If you know, if you’re an executive, by the way, let’s back up for a minute. Folks to our listeners, if you’re an executive, especially if you’re a CFO, you could be a COO for that matter, CEO, obviously, too. CEOs are looking at visionary for the you know, the company and in the big picture and all of that duty drawback would be something more from an operational perspective, and more from a finance perspective of improving your margins and all that. So I don’t think the CEO, they may be of interest to a point, but I think you would have a better opportunity to talk to your finance and your your operations, executives, in my opinion. Now, again, Dave, you know, correct me if I’m wrong, because I’m dumb as a box of rocks here. So I, you know, it’s like, tell me on that I’m looking at this from a standpoint that if I’m going to get support. Now, let’s just say, like, all right, CFO, that’s where I see the biggest bang for the buck, buck, because we’re spending money duty drawback is going to help you improve your cash flow. That right, there is going to be something that’s like, okay, that interests me. So you got to use language that, you know. It’s, you know, well, we’ll, we’ll get money back. Okay, fine. When you start saying it will help you improve your cash flow or minimize cash flow, hits again. The executive, okay, you’ve got my interest

28:31

right? Or supports creation of jobs, or is going to, you know, finance, a new team in Europe that we don’t have established right now, right? Any number of things. Or, you know, hey, we have a pipeline for bonuses that we didn’t have before, any number of different ways that that can be utilized. Yeah, understand what those, what those key things are for your business, because it’s not going to look the same for everybody.

Lalo  28:53

Let me ask this real quick. I mean, because you all are talking about, you know, like, like, you say, Andy, you know, this is, this goes straight to your bottom line, etc. I mean, I know, yeah, like, literally in the thick of COVID in 2020, 2021, I know I talked to some clients here, where a global Training Center, where we provide training. We were doing training. We continue to do training for international trade. Of course, you know, we were just doing it virtual, but we had clients that would come to us and tell us, I need to learn more about this, because I know of X company, for example, and in fact, one of them did attend our training that, believe it or not, they went back and did their drawbacks, and that’s how they kept their doors open. You know, they went and got couple million, two or 3 million, whatever. And drawback, and because they were just not able to sustain the normal importing, exporting, remember, they pretty much shut down China and everything. But anyway, to your point, Andy, and then, and then I’m going to bring this in from from the client. Perspective, some of the reasons that I see that they don’t jump into this, or they don’t go into drawback is, and of course, we can’t sugar coat it. There is a lot of data requirements there. I mean, y’all are talking about that as well. What do you see, Dave, do you see that a lot of people, a lot of companies need to do this with a partner, you know, like a broker or a consultant. Well, I guess a broker is ultimately who files it, but you know someone who helps them, holds their hand, or is it like pretty feasible for a company to do it on their own, in house?

30:37

So you need it. You need a broker in order to you know his customs business, you know so drawback you need that in order to transmit your drawback claims. But hopefully a good broker will will say that there is a lot more that they provide in the service that they provide, walking a customer all the way through. There are so many different types of regulation, policy, co chair layout pieces, statutory limitations. There are ACE business rules. There’s a number of different things that folks need to be tuned into, as well as errors on drawback claims that come through. It’s very difficult to maintain all of those things and think that you can handle that on your own without some sort of hiccup along the way, and so you know a broker who specializes in drawback is going to benefit you greatly in reducing the headaches that you may have over the course of your drawback program, because we also have established relationships with each of the drawback teams, with the supervisory personnel, with the Office of regulations and rulings, with the Office of trade, and so we are able to kind of look at what CBP is going to ask in advance, to help prepare you and your compliance team for what you’re going to walk through. Not to say that it’s not going to have it’s not going to be completely seamless, right? It’s the data we receive also needs to be where we need to be. But there could be situations where, you know, that can be complicated for folks, if they have to pull down from multiple systems at the same time, right?

Lalo  32:11

And it’s not like, it’s not like a broker I if I’m if I’m not mistaken, most, if not all, brokers will not charge you for this unless they recover money, right? Yeah,

32:22

right. So it’s, you know, they’re, in some instances, brokers will work with you for years before you’re paying something out if, if it takes that long to get over the finish line. And some complex programs, you know, take a little bit more time when you’re talking about different things that you have to approve. So having a broker, in my opinion, is the right way to go

Andy  32:40

well. And here’s one of the things too, that that especially in corporations and whatnot folks, is getting an expert on helping you with your drawback process is highly advisable, because, just to try and give a parallel doing drawbacks can be as complex as following an income tax return or modifying an income tax return. Let’s put it that way and things of that nature. So you know the need for that level of expertise. It’s worth it, and you know you’re going to get what you pay for. So your standard, everyday type stuff, you know, the HR block kind of stuff, could go down that road. And there’s people developing, you know, software for that. But most drawback situations are, are pretty complex. And I you know, so I would tell you, in my own personal case, there’s no question I’m going to hire so a firm that knows drawbacks and and has an expertise in that to have my back on that so so well. All right, any we’ve been talking through this, I guess we probably need to try and wrap up here. But let me ask this question from your perspective, Dave, is, what is it that you think would be the three top things, if somebody is, you know, considering doing drawbacks, what would be maybe the top three actions here that you can think of, that you can recommend. What would be next steps

34:25

you haven’t already make sure that you’ve done your analysis to determine what your drawback potential is, you got to start there to determine is it worthwhile for my company to move forward. If I can only get 10 or $15,000 in drawback, it may not be worth a headache to you know, the juice isn’t worth the squeeze, right? Come up with the analysis. And then you know. Second thing, find out who your partner is going to be, partner with a drawback, expert like you talked about, but make sure as well. And maybe, thirdly, that you have all of your ducks in a row. Am I able to source from my suppliers, from my. Forwarders, from my brokers, all of the information that I need to support my drawback program going back in time and going forward. And if not, I have to work to establish a process in order to do that, but make sure that I have those things to make sure I’m buttoned up. If customs comes asking questions and they will, that I have everything that I need to answer those questions with a passing grade, without any sort of concerns that the issues that I’ve or the information I presented will meet the requirements that are outlined in the statute, in the regulations, well,

Andy  35:32

and what you were saying is doing the analysis, that’s where you’re whomever you’re going to partner with that’s where that expertise comes in, or even a drawback consultant, if you will. They may not do the drawback entry itself, but having somebody, they can guide you through that analysis. And you know, it could be something where you have somebody come in and actually sit with you and go through it, but they can predominantly even just consult through and say, okay, here are the questions asked. Here’s the information you need, and then that gives you that empowers you as a compliance person to go and navigate within your company, to go get that information. Now you pull it back, it’s like, okay, now I’ve got the information. What do I need? You know, when I’m doing my analysis then, well, then now you pull that expertise back in to say, all right, help me analyze this rather than paying somebody. Is like, Okay, go get the information. You’re you’re paying it over. You know, it’s an overpaid clerk. It’s like, tell me what I need to go get I’ll go get it. Pull it back. Makes you more productive. Makes sense to win, win.

36:42

Yeah, yeah. And after you do that analysis, sometimes you find you have more than one type of drawback you can apply for. So you know, you know. And about half of our clients have one type of drawback, and then they find out through this analysis that, hey, there’s these other products that I hadn’t remembered from three years ago, so there’s other opportunity that they don’t even know about until the analysis is done, so you

Andy  37:03

can go back five years. So that’s it’s pretty slick, yeah. Well, Dave, listen, I appreciate your coming on and with this as we start seeing some things with the legislature going through, or whatever you see, some things on that come back to us so we can highlight what’s in the appropriate Bill, who may be sponsoring it, or if it’s on the table and we need to get a push to get somebody to sponsor it, we can talk through that on the show and hopefully get some actions from the audience here, which be

37:36

great. Would love to have that that sounds great. Love to follow up. Thank you guys for your time. I appreciate it very much. You bet you

Andy  37:42

Lalo, anything

Lalo  37:44

from you? I just want to remind everybody that we’ll have Dave’s information in on the show notes. You know, you can contact him through that and or check out our YouTube. YouTube also has a description detailed information about, not detailed, but contact information. That’s what I meant to say, contact information for Dave and as well. Check out our any and all LinkedIn posts that we may do. He’s he’ll be tagged on there as well. And you can reach out that way. But you know, please do check those out and Dave, again, thank you for your time and for reaching out and and putting out a notice out to everybody else. On my end, if y’all do want to come on the show, let us know, because fresh content is really good. So thank you, David. I

Andy  38:36

appreciate it. Appreciate your time. Thank you. Well, folks, we’re going to turn it back over to We hope you have a fantastic day. And again, let me ask seriously, help us to grow the show. Like us, share our show, follow us, subscribe all that kind of stuff. We greatly appreciate that. With that, have a great day. Thank you

Lalo  38:56

very much for joining us. Simply trade is brought to you by the generous contributions of global Training Center. You can follow the show and GTC on LinkedIn or Twitter and other social networks. Make sure you check out the show notes in the description for a full rundown of today’s show with all the important links. Also make sure that you share this with a friend and subscribe on your favorite streaming platform. We really like hearing from you if you enjoyed the show, make sure to rate and review wherever you listen to this podcast. If you or someone you know would like to be a guest on the show or would like to sponsor simply trade, or suggest any topic you would like for us to discuss, please contact us via email at simply trade@globaltrainingcenter.com or you can DM us on Twitter at simply trade pod. Thank you again for the privilege of your time. Happy trading. Simply trade is not a law firm or an advisor, the topics and discussions conducted by simply trade hosts and guests should not be considered and is not intended to substitute legal advice. You should seek appropriate counsel for your own situation. These conversations and information are directed towards listeners in the United States for informational, educational, entertainment purposes only, and should not be substituted for legal advice. Advice, no listener or viewer of this podcast should act or refrain from acting on the basis of information on this podcast without first seeking legal advice from counsel. Information on this podcast may not be up to date, depending on the time of publishing and the time of viewership. The content of this posting is provided as is, no representations are made that the content is error free. The views expressed in or through this podcast are those of the individual speakers, not those of their respective employers or global Training Center as a whole. All liability with respect to actions taken or not taken based on the contents of this podcast are hereby expressly disclaimed.

40:34

You.