The Hidden Risks of Importing: Tips to Stay Off Customs’ Radar

Machine Automated Transcript:

Folks, we’re on for a simply trade podcast show. This is going to be a good show, good discussion. And I am looking forward to today, because we have a two things that are happening. One, Lalo and his wife are out traveling, so while we’re recording this, so hopefully they’re going to have some great times out on the West Coast and enjoying some time with their family and whatnot. But Renee cucarelli is on, did I say it? Right? Perfect. All right. So Renee is graciously sitting in and let me tell you something, folks this, this lady runs circles around me, so she’s so good, so smart, and is a great fill in for Lalo. So like, welcome to the show, Renee, thank you. Andy,

hey, last Anne says, I’m now part of the team. Cindy

Deleon is on and I Cindy man, I tell you, it is always a pleasure getting to see you at the conferences and around but thank you for coming on our show. This is going to be great.

Thank you for having me. Yeah, I

love it now. You had a great career in on the custom side, and I believe you were in the audit side of things, right? So it’s like, ah, and so, and that’s one of those things where I’m looking forward to this discussion because it’s like, you know, you could probably we have a show that we talk about simply trade crimes, and usually we have an attorney on there that is talking about a case that somebody got, you know, arrested or convicted on something. And at some point you’re, you go through the case, and we talk about the issues, and the statement comes out as like or a question, what were they thinking? At the same time, I’m sitting here going on the audit side of things, I’m sure you have some stories of cases that you’ve encountered, going, what were they thinking?

Tons of them, tons of them, old ones and current ones in the consulting practice. So, I mean, she’d be

awesome on simply crimes. I have insider information that with a company I used to work for. I was her one of her top five nightmares. Can I say nightmares? Cindy? You

know, I would, I would call it most challenging

projects. So she she’s got some great and she saved my tail. Can I say that?

Well, you know what that that lends itself to folks, if you’re in the midst of, like an aha moment, a moment, we’ll call it. And you’re trying to deal with whether you’re the owner of a company, whether you’re in a compliance with whatever position you are in. And it is so important to get experts in to give you the appropriate guidance. Don’t try and take this stuff on by yourself, because one discovering an issue is one thing. You may find that when bringing in some folks and they start digging in, it’s a much deeper issue, or multiple issues. So all that to say, get your experts in to help you discover what, in fact, is going on, and secondarily to that, then get your appropriate legal folks in to cover your backside as well. But anyway, so yes, Cindy, you are, have your own consulting firm. Have for quite a while, 17 years, yes, and you are very well respected, so I attribute that. So anyway, so how’s it been going in the industry?

It’s been going well for for de Leon trade. And you know, one of the things in preparing for this, and I was telling Renee, what I try to tell companies, is find out what makes you sexy to customs, because, is it a free trade agreement? Is it a first sale program? And I was, I was kind of telling Renee and painting a picture, an auditor gets an email with a list of companies that they get the opportunity to audit in that fiscal year, but then they have to develop what they want to look at. And so if you’re an importer and you are a director of trade compliance, a senior director, an AGC, whatever you are, and for those C suite people listening to this podcast, listen in and buckle up, because you really need to understand these things and support your teams, but knowing you know where the biggest ticket payout is for a customs auditor is what’s going to make you most sexy. So it’s one of the things I really like to remind people,

yes, what are those things? Tell us. Tell us what makes it what makes us? Actually the customs as an importer, yeah.

So, I mean, gosh, if number one auditors love data. I mean, I used to get, you know, I track data or ACE data now, and it’s just like a kid in a candy store, right? And so if you look at your data, and customs were to disallow all of these free trade agreement claims, let’s look at usmca as an example, how much money is that going to be worth to them? If all of your goods are unconditionally duty free anyway, then is that really where the biggest bang for your buck is, or is it, you know, a first sale program, you know, so you know if customs can take issue with your first sale program and cause a huge duty underpayment and an audit report to collect revenue on first sale. You know is that your what makes you sexy to customs, I think also one of the biggest things I’m seeing now. And remind I

realize I work for customs 17 years ago, but I’m interfacing with customs regulatory audit all the time for the last 17 years, we’re actively working on audits and investigations, criminal cases, DOJ cases, all kinds of stuff, whistleblower cases, and so one of the things I’m seeing a lot of right now is a lot of companies said, You know what? We’re going to go in and get some money back. We’re going to show our executive leadership how worthy we are, we’re going to file all these PSCs and refunds, refunds, refunds on 301, exclusions. Guess who’s getting targeted now for audits, a lot of those companies that not only request exclusions, but then change the tariff number first and then requested an exclusion. So if that’s a bucket you fill in, just know that you are quite sexy to customs right now.

And for our listeners, stop for a second. You mentioned PSC as a post summary correction. And so that’s basically an entry went in, and then you’re correcting it and changing something on the entry. And so again, on the surface, there’s a lot of folks that will say, okay, yeah, we can do this if we change our Harmonized Tariff number the classifications you just mentioned, from HS number one to HS number two, whatever that it may be. And it’s like, wait a minute, the widget is what it is. So if you change that classification, and in a sense, you know, these auditors are not stupid, they’re going to look at it and going, you’re just changing this. So you can try and claim this, did the widget itself change? And if it did, you were misclassifying it. So then you haven’t, you’re opening up another can of worms to go back even further, or as far as they can, to say, well, maybe you’ve been misclassifying all along here. So it’s just, it’s you got to really weigh this out and go through that. So

that’s exactly right. That’s exactly right. And I would say the last thing that we’re seeing a lot of right now is 80 CBD cases, anti dumping countervailing duty cases. So if you have product that is flagging an 80 CBD case, but you are not, you know, paying any anti dumping duties, or if you have a tariff number that’s really close to one that’s, you know, potentially subject to adcvd, or you have a country of origin that is, you know, really close to the country that is subject to the order. You know, these are all things that make you sexy to customs. Customs is looking at that, that potential mister classification at the seventh through 10th digit level that now puts your goods from, you know, flagging adcbd. I’m not saying the HDS number alone makes you know your your good subject. We all know that this is not my first rodeo, but you know, it’s some, definitely something that flags the case

well. And here’s the thing then. So based on what you were just talking about, we’ve mentioned this before, anti dumping and countervailing duties, is what you’re referencing. There is this is why it’s so important when you have a new product and and you’re looking at you’re adding a part to your inventory, you’re adding a new product to your inventory, that you’re selling whatever to you know properly, vet that and go through and make sure that you’re sourcing it appropriately. But you know, the components on everything, maybe you’re dealing with somebody that is not on the sanction list, that everything’s turned out okay, it appears that it is not part of the forced labor prevention type situation. So it’s like, it’s made with legitimate labor, great, and then only to find out that there’s a component that would qualify for add or CBD, right? Yeah,

yeah. And you know, I know you guys have done a lot of forced labor. Or podcasts over the last, you know, several months. So we’re not, we’re not going to go into that today, although it’s, it is one of my favorite topics to talk about, just to raise awareness. But just think about it. I mean, forced labor.

You’re not paying money to have someone manufacture something for you, anti dumping goods that are sold at a lower than fair market value. Could there be some synergies there? Just think about that.

And let’s remember customs is a revenue agency. That’s what

they’ve designed to do. One of the, one of the things that I really love to talk about, because it’s not talked about enough. And I’ll tell you this, Renee, and I wrote it down just for you, Renee, because I thought you would find it funny. How much undeclared crap would customs find in conducting an audit of your evaluation. Let me say that again. How much undeclared crap would customs find? And begs the question, what is crap? C, R, A, P, P, what’s commissions, royalties, assists, packing and proceeds and so many companies just are missing the bus in this area. You know, trade compliance people don’t have a good relationship at times with their finance departments or with their controller and accounting departments. The controller and the accounting department is always in a close. Oh my gosh. They’ll tell you every time I’m in month end close, I’m in quarter end close, I’m in year end close, I’m in pre close to the close of the following close. And it’s like, no, that is not a good enough excuse. You really need to build a liaison with finance and accounting and work with them to conduct regular reviews to make sure that you know there aren’t, there wasn’t a new royalty agreement that was put in place that now affects your valuation that you weren’t aware of, and you know you need to do something about. And just because there is a royalty agreement in place doesn’t mean that royalty is dutiable. You need to know what royalties are dutiable. Royalties aren’t dutiable. You know, do you have assists that you’re providing to your foreign vendor? So many companies are looking at near shoring I mean, it’s like the most hottest topic right now. And I have my whole, you know, opinion about that, which I will, I will not share at this point in time. Who doesn’t love Kiko, right? So Kiko Zuniga, who works for the NCB FAA, gave a talk here in Houston, in the great state of Texas. Oh, and I have my hat to Andy. So there you go, the only one. And he mentioned that so much of the land and the buildings for manufacturing and warehousing that is available in Mexico is being bought up by Chinese companies, it is okay, and it’s a huge it’s a huge issue. And I’ll tell you, a lot of you companies that are out there thinking about near shoring don’t think that your uflpa risk is going to go away, or that your ad CBD risk is going to go away, or that your 301, risk is going to go away. Because customs can see when goods are imported from China into Mexico. You using software. You know, they have software tools at telemet and Mexico, custom sells its import, export trade data to many different companies, including software providers like Sayari, who I think, have probably been on your podcast, I’m not sure, and other companies, as well as us, Customs has access to this type of information, and they have a subscription to some of these software tools. So it’s really important to know that customs can see when those raw materials are being shipped into Mexico for use in manufacturing. And you know, some of that is going to have an impact on 301, applicability on usmca qualification and on free trade agreement. So, you know, it’s just something to think about Cindy,

that that’s one thing that let’s let’s stop for a second here is that when I’m dealing with different companies, or to our audience, there always seems to be somewhat of a disconnect between the purchasing or sourcing group versus the compliance group, because the compliance a lot of times on the tail end of things, or is one of those, you know, get out of the way. You know, do you know, just do your regulatory thing on the side. Let us go out there and purchasing is looking at bigger, better, faster, cheaper. So they’re trying to source, you know, mainly just, just on cost of the manufacturing of that widget. The problem is, if you look at it holistically, it’s like, Okay, now the country of origin is such that there’s going to be a duty rate involvement versus a duty free situation, or the

transportation, or and or transportation. In rates for that, because the transportation is going to be a higher cost, because it’s a longer way. But then on the other side of that is an other thing they’re embedded in, that it could be like you’re saying the nearshoring, near shoring just means that you’re you’re finding a source that is geographically close to you, right? And so in that realm, it’s that, well, what are the components of what you’re buying? Where are they coming from? This is that tier two, tier three type supplier, folks. So as we’re looking at this, you really need to develop, if you’re in the compliance arena, you need to reach out and make sure you develop a relationship with that sourcing, Purchasing Group. Conversely, purchasing, sourcing folks, you need to reach out to your compliance folks, because here’s the other thing, you’re out there, you find a great price, but then you turn right around, and when it starts coming in, there’s all these other regulatory type things that come into play the forced labor No, there’s a component in it. Can you imagine that you find a great source for some widgets. You bring in 10,000 of them, and they’re stuck at the border and they’re either seized or refused. You found the contract, you found the price on that, but you didn’t do the whole vetting process, and now all of a sudden, it is hung up because there’s something in there that shouldn’t have been. And so all that to say is, folks in today’s world, Cindy, hit something there, all this data, all this freight movement that’s moving back and forth from one country to another, and all that, all of that information, customs sees that, and they’re tracking that, so they know when something’s coming around. And they’re just looking to say, well, this raw material could be cotton from the, you know, China, then from the Uyghur region or something. It’s going to be manufactured into shirts, pants, whatever, articles. And when you look to see who’s importing it, and they’re going to look to say, Uh huh, it’s uh they got imported into the Guadalajara area, and this is coming out of Guadalajara now. Gee, let’s look and do a sampling. The DNA on that is from China. So guess what? Stuff is hung up. So you need to vet it as a team in today’s world. Would you agree with that?

I would, and let me tell you a story, and I’ll keep the name of the company off the record, and I’ll even keep the commodity off the record, just so no one so the guilty in this case are protected, to some extent, but I had a client who was under a CBP audit, slash investigation for 80 CBD evasion. Okay? And so when we were going in with the with the attorney to help the client prepare, we asked them, you know, are you making this in in India, or are you buying it from China and shipping it to India, no, no, or making it in India. So I went into my software tool to see if there were shipments of the finished good from China into India. Now, China does not release its export data, but India does release its import data. And a lot of the tools, a lot of people think the tools have all global import and export data, and that’s a lie. They don’t, none of them do you have to really know which countries import and export data you need, and then determine which software solution has that data. So I went in there, and then I was able to see it, literally. Was able to see, within like two minutes, that this company was importing finished goods into India. And so I just turned my laptop around and show him, and he, you should have seen, look on his face. He’s like, Oh my God. And then he just broke down and started admitting all the things he had done to me and the attorney, and all the, you know, bad things that were taking place. Were like, Oh my gosh. Okay, let’s I won’t do it anymore. I promise I’ll never do it again. And so, so, yeah, so, I mean, imagine, and then every auditor in customs, badge toting auditors, have access to these tools. So people, customs is not stupid, as Andy said. And

you he lost his attorney client privilege. Frankly, with you in the room, I would have said, Hey, we are really strict. He didn’t, okay? No, no,

we work under attorney claim privilege with the law firms, just like we did. Renee, you’re

right. Okay, I was like, but make sure you have that privilege, right? 1,000,000% Yeah, all right.

So as we’re talking through this is that what would be some of the key things that you’re you would recommend that people need to do if they’re coming across an issue, or should follow up or I mean, where do you want to go here is in advising some folks here,

I find it funny, ironic, almost, that most importers and. People in this, you know, responsive responsibility position. What do they fear most? They fear the audit, right? They fear the audit. They fear an investigation. They feel fear a CF, 28 request for information, right? So you fear it most, but what are you doing to prepare for it in the event that happens, right? And so my recommendation is one of the first things CBP does when they engage with your company in an audit situation, is they send you the questionnaire. That questionnaire is online. If you haven’t filled out that questionnaire, fill it out, and when you start reading those questions, you’re gonna be like, Oh my God. I don’t know what I would say to that. I don’t know what I would say to that. And I’ll caution you, you as a trade compliance professional, should not be responding to every question in that questionnaire. If there are certain value questions, finance should be answering, if there are procurement questions, procurement should be answering. If there are engineering questions, engineering, executive leadership, logistics, receiving all these people need to be involved. And if you don’t know who all those people are within your company, that’s a problem in and of itself. You need to create a working group within your company and have liaisons within finance or accounting and procurement and logistics and executive leaderships in order to ensure compliance, you can’t do it alone. So that’s one of the first things I recommend, is respond to that questionnaire and see if you’re ready. The second thing I would recommend is do an audit. Do an internal audit, because you walk around thinking, I think I’m doing good, you know, I think I’m golden. I’ve got a ton of procedures. Look at my manual. It is that big. It’s great, but you don’t really know how effective that is until you audit it. You know it’s like, it’s like me telling my teenager, hey, go clean your room. And he says, Mom got it. It is spiky span. Let’s be real, ladies, he’s a 16 year old boy. It is not going to be spaghetti span. His idea of cleaning his room is taking his foot and, you know, shoving things under the bed and, and, yeah, and, like, putting the towel in the hamper. And you guys have been there. You all have kids out there. So, you know, making that’s not customs version of spaghetti span, just so you don’t so, so going in and doing internal audit, and if you’re going to do that audit, make sure that it’s going to give you metrics so compliance rates. So because you need to have metrics and compliance rates in order to be able to share with executive leadership, if you want them to give you more resources, or if you need them to give you money for software tools or, you know, new positions. And then the last thing is really looking at your procedures. Your procedures need to have teeth, okay? And not the kind that are removable, okay, like the ones that are nice and fully functional in there, you know, they you they need to have teeth. And in developing procedures. If you don’t have procedures, I tell people all the time, you know, develop your procedures, implement those procedures, and then go back and retest whether they’re working properly, doing another audit. And then where you have gaps, tweak and adjust and strengthen those procedures. And you keep doing that, you keep retesting, and you keep updating, and you keep tweaking in order to make sure that your compliance is at a point that you need it to be. And never audit yourself. Never audit yourself, because that’s just, that’s just for auditing. So

let me ask you this, because a lot of times we would bring in, we wouldn’t, you know, audit our we

would do an internal audit, but then we’d have a mock external audit, right? We would bring someone like you and Cindy and say, Hey, we want you to do a mock external audit of us, which I think is a phenomenal idea, because, to your point, we don’t, you know you with your experience with us, customs when you worked at CBP, you know, what’s sexy, where’s the crap, right? You know, if the processes have been implemented. I mean, sometimes I would ask the people that work for me, hey, I’m going to pull out one action line, 27 on this SOP, show me. Show me the data that says you did this. Show me the document, even to my own team. So, I mean, and Cindy’s company and herself are so experienced in that I think an external mock audit is also phenomenal. I

you know, selfishly, I disagree. However, I caution you, okay, because there are a lot of companies out there doing these mock audits, and you really want to make sure that the people doing the audit are experienced. And so if you’re going to hire someone, don’t just hire a company. Ask who, who is going to be doing that audit, not the sexy partner that you know is coming out to wine and dine you, who actually is doing the audit do that? Does that person have the requisite experience to do that audit? And so I. Think that’s really important, because the three of us here, Andy, Renee, you and me, if we did an audit on a usmca, claim, the methodology for that audit and the possible conclusion for that audit could be different for each of us, right? Some people, let’s, let’s pick on Andy, because he’s a guy, and we’re always going to pick on guys. Andy. Andy may just look at the entry documents and say, hey, it came from Mexico, so it qualifies. We’re good to go, you know. And Andy, I know you would never do that, but humor me. Renee might say, No. I mean, come on, we need a certificate of origin. And so she’s gonna look at that certificate of origin, and she’s gonna say, okay, that certificate of origin is valid, you know. But if I come in, I’m going to say, Do I have a certificate of origin? Did it direct ship from Mexico in this instance? And does it meet the Rule of Origin? Is a Rule of Origin an RBC rule? Is it a terror shift rule? You know, does it have a certain exception to the terror shift rule? Do we have any other types of, you know, nuances to the rule that would cause it to not qualify, and can we document it? You know, do we have the requisite support to document it? So you really need to, when you’re being audited, whether internally or externally, you need to get into that level of detail of what you’re getting, because it’s just not going to be the same otherwise.

All right, so here, let me ask this question. Is that if you’re looking to try and do some things, let’s let’s go back. I want to summarize what you had said there, Cindy, is, if you’re in the compliance area and you’re looking at, you know that an audit is coming, or you want to be prepared for an audit, you hit four different things. Four things is the first one was make sure you have established relationships with key people in all those different areas, purchasing the transportation, of course, you know, you got your compliance. You got your accounts receivable and accounts payable. That’s key on both of the not just accounting your legal side, from your, you know, contracts to, you know, if you’ve got a trade attorney in there or a firm that you use your IT department, specifically into your supply chain, to your systems, your company and all that. Then you have your, you could have even your your security, literally physical security of warehouses and distribution centers your operations. I mean, we’re going on, but it’s like that takes time to establish those relationships. That’s one thing I love. The other idea is that, in looking at it, you’ve got to do your own thing where it’s like, Okay, let me pull up this questionnaire and say, let me start going through this. And as you’re looking at, I thought that was profound, where you’re saying, Cindy, don’t look at it as you’re having to answer all those questions. You need to reach out to finance. You need to reach out to sales or customer service or logistics or whomever. And as you’re gathering that information. So one of the things that I find is, as you’re going through that you’re going to that questionnaire is going to help guide you to say, this is showing me what I really don’t know. All right, to that extent. Then you go through and you say, Okay, now let’s do an audit where you need to look at it and say, you know, let me look to check to

see, you know, how good are we. And you can do yourself, you know, just in checking yourself. But then you really do need to do and hire somebody to come in and say, you know, kick the tires. Let’s find the weak links, whatever the case may be, so you can look at it. I’d rather do that than wait till customs comes in and does an audit. And then the last thing is, then you’re going to modify, either develop and or modify your policies and procedures to adhere to, you know, the findings and as a solution. So with that, let me just say this, in doing an audit, it’s one of the areas I always recommend, and Renee, I’m going to ask you this question, is that when you’re doing like a self audit type scenario here in your past history, I always recommend you literally get with the Audit Department of a company. There’s usually and it’s usually on the finance side. It’s usually more accounting side, but they’ve got audit experience. They know how to deal with that data that Cindy was talking about, is like and all that. And

I was gonna the companies I work for, Andy, the internal audit guys or folks male and female, did not have trade compliance experience. We actually were training them. Yeah, we were training them

so, so you hit the nail on the head, and I’ve seen internal auditors be successful and be unsuccessful. And I’ll tell you why there’s a difference between auditing tests of controls and then auditing tests of compliance. And I’ll tell you the difference. Let’s say we’re. Is an importer, and she has a procedure that says, on a quarterly basis, her and her team are going to do a Post Entry audit, and that audit is going to cover 100 transactions, and that audit is going to test tariff classification, valuation, free trade agreements and so on. Okay? So if you’re an internal auditor, you can say, I’m going to look at the written procedures. I’m going to identify this control, which the control is a Post Entry audit process, and they’re going to test that that Post Entry audit process took place. They’re going to say, Renee, show me the completed Post Entry audit results for q3 2023, Renee says, Yep, we did it. Or no, we did it. Oopsie, you know. And she gives that information over to the internal auditors. The test of compliance Andy is, in those 100 sample items, did the auditor come to the right conclusion? An internal auditor isn’t going to be able to make a determination whether it’s truly that tariff classification was right or wrong, you know, or truly that valuation was right or wrong. So that’s kind of the limit of internal auditors. There’s a lot of internal auditors doing these types of audits, especially for Sox compliance. Our brains actually compliance, but, but they can only do it from a test of controls standpoint, and not a true test of compliance, because they just don’t have the requisite us, customs, trade compliance experience. Hope that makes sense.

Yeah, and for those that man, I haven’t heard Sox in a long time, that’s the Sarbanes and Oxley, but that’s still out there, folks, and it’s actually can work really well for the compliance area, because the Sox compliance is basically you’re crossing the T’s and dotting the i’s on every part of the transaction throughout the company. And it’s that’s a good thing. So as I think

about Final thoughts you guys, I just come back to training, and I think about global Training Center, and when I came out of the government, and I didn’t have access to, you know, government training anymore. One of the places I personally went to, and my team has gone to, has been the global Training Center. So I’ve been, you know, a fan of global Training Center and Lalo and team for for many years, you know, over a decade. And I just think that training solves so many problems. It solves ignorance. It helps to bring consensus. It helps to build liaisons, because a lot of times, people are reluctant to engage and involve just because their lack of training and awareness and comfort.

And once you give them that training and awareness and comfort, it really opens doors, but you have to do it at the right level. I cannot give a C suite audience technical training on RVC and tariffshift. They don’t want to know about that. You have to, you have to train to your audience at the right level, and otherwise you’re going to lose people. So I think that’s so important, shamelessly, if it’s okay. I just want to remind everyone that we just opened registration for the advanced topics and customs compliance Conference, which last year we were in a sold out situation at 500 attendees. It’s in Houston, February, 5 through seventh of next year, we will sell out again. I’m sure of it. And this is, this is a conference really not meant for really new people in trade. It’s you’re going to your eyes are going to roll into the back of your head if you don’t have at least five years in probably a little bit more than that. This is really intended for senior people, senior analysts, directors, senior directors, because we’re trying to get beyond the basic levels that you can find. You know, in many different places, we’re trying to really focus only on the advanced topics. So I encourage you to check out our website@customsconferences.com

With that, let me ask a quick question on that with your conference. If somebody’s looking at, obviously, you’re getting into the nitty gritty of some really deep topics and whatnot. Would it be advisable for somebody that’s, let’s say, a senior compliance person that’s going there to bring along one of their C suite executives? Absolutely,

I think it would be really good idea for them to do that, especially your finance controllers, these type of people. This coming year, we’re going to do a technical computed value cost submission session in Spanish only because I need controllers in Mexico to understand some of these laws and regulations. So definitely bring your procurement people blow their minds. And if you’re a procurement person and you’re listening to this podcast, spread the word other procurement people, because if you understand and embrace trade, you’re going to be that much more effective in your job and procurement if you look at trade as. And you know, as just a problem or an impediment, you know, I think that’s going to cause you an impediment down the road. So just embrace your trade people. Trade people are good. Everything’s

interconnected. For crying out loud, yeah, Cindy, that’s awesome. Thanks. We’re looking forward to your conference, and we I’ve thoroughly enjoyed this discussion, great facts, great takeaways. I mean, we now we know what crap is and what’s sexy to customs. So those are, you know, in addition to do the questionnaire right and get your advisory committee set up, or your Trade Council or task force, whatever you want to call it, so that you can liaison and communicate and develop and build relationship. Well, I

was just gonna say we’re gonna have Cindy’s contact information and links to her website and all that with the show notes along with a global Training Center. Please take a look at that and in get yourself up to speed on some of the issues that you’re you know, we’ve talked about and all said and done, we greatly appreciate you. Cindy, it’s always a pleasure, golly, it’s it’s always great to get to see you. You

too, you too. Thanks for the invite. Great to see you both as well.

All right, folks, with that, we’re going to say goodbye and have a great day.