Dave Corn is executive vice president of Comstock and Holt and started his drawback career in 2011. He serves as co-lead for the trade in the Trade Support Network’s Drawback Working Group, leading efforts to build and transform the duty drawback program through changes to policy, business rules, regulations, and statutes. Corn also serves as the co-chair for AAEI’s Drawback and Duty Deferral Committee, as the vice chair for the NCBFAA’s Drawback Subcommittee, and represents the New York/New Jersey region as a member of the board to the NCBFAA.

In January 2024 he was reappointed to serve on the 17th term of the Commercial Customs Operations Advisory Committee (COAC) where he was selected by CBP and his peers to be the COAC trade lead. Corn actively discusses drawback with congressional representatives from New Jersey and New York as well as the U.S. Trade Representative’s office. He is a frequent speaker on duty drawback in venues across the country each year, and at AIAG’s upcoming North American Customs and Trade Town Hall on November 7, 2024, he will be co-presenting with colleagues Dawn Olesky (KPMG) and Christine Dubicki (MIC Customs Solutions) on “Driving Value and Compliance with Duty Drawbacks and Export Modernization.”

AIAG: What are some common misconceptions among automakers and suppliers regarding duty drawbacks?

Corn: I’m not sure about misconceptions, but it’s always good to review your program to determine if everything is working in accordance with the law, regulations, and policies that CBP has outlined. There are consistent questions for drawback claimants to ensure that what they’ve claimed is accurate; claimants want to be able to hold on to the drawback dollars they’ve collected when first filing claims, instead of finding out later that money must be returned. Diligence is vital!

AIAG: Is the auto industry taking full advantage of duty drawbacks?

Corn: We always believe that there’s an opportunity for growth and expansion, as some companies only focus on the low-hanging fruit right before them and might miss what else can be done to supplement their program.

AIAG: What can they do to improve their performance in this area?

Corn: Have they looked deeper into their own data? Analyzing ACE data can be an eye-opener to determine where drawback opportunities exist. Conversations with connected parties in their supply chain would be the next step. Do you purchase imported parts from other companies that are used in the production of exported articles? Do you sell to customers here in the United States that export those articles thereafter? Have you investigated the opportunities for drawback trading through an independent third-party? There are many ways to take a holistic look at each drawback program to determine if more can be done to expand the program and increase drawback returns. 

AIAG: What are the key elements needed to advance export modernization?

Corn: This effort is certainly linked to the drawback process, where the trade has hoped for a connection to date and fact of export for many years. When the Electronic Export Manifest (EEM) process is finalized for all modes of transportation, the updated elements in the new regulations will allow for closing out of certain transactions like drawback, in-bond movements, and temporary imports. There are additional benefits connected to cargo processing, streamlined reporting, and a potential for reduced costs and penalties. The industry should be aware of the potential changes as they happen and respond accordingly when necessary. 

AIAG: How can the trade community improve collaborations around export modernization?

Corn: Continue to stay focused on changes as they happen and be ready to respond. If regulations are released and a comment period is provided, it’s important for the industry to realize how those potential changes may impact how merchandise moves throughout the country in preparation for exportation. Be sure to find others in your industry who are willing to respond as a whole to proposed regulatory changes as they’re released. 

AIAG: What can attendees expect to learn from your presentation?

Corn: For a program that’s been in existence since 1789, drawback is frequently being discussed. There are trade bills that are focused in on specific areas of the drawback process, changes to policies, business rules and validations that constantly need to be reviewed. We’re also nearing a point of regulation for EEM modes of transportation that will need industry comments as they are expected to change how export modernization looks and feels going forward.

The AIAG North American Customs and Trade Town Hall is packed with a full day of sessions and networking. You can review the full speaker line-up here.

Attendees can earn 6 NCBFAA credits (National Customs Brokers & Forwarders Association of American) for participation in this event. A block of rooms is set aside at the Marriott Courtyard Livonia for $129 per night, but is selling out quickly. The event includes lunch, a networking reception, and exhibit hall.