CSMS Message: 01-000078

TO : ALL ABI BROKERS.

TE : 01/11/2001
ENT-14:FO:TP:IA:TA LH

TO : DIRECTORS, FIELD OPERATIONS
PORT DIRECTORS
ASSISTANT PORT DIRECTORS, TRADE

FROM : EXECUTIVE DIRECTOR, TRADE PROGRAMS

PASS TO: IMPORT AND ENTRY SPECIALISTS, INSPECTORS, BROKERS, IMPORTERS
AND OTHER INTERESTED PARTIES

SUBJECT: IMPLEMENTATION INFORMATION ON THE "NAFTA PARITY" PROVISIONS OF
THE CARIBBEAN BASIN TRADE PARTNERSHIP ACT.

BACKGROUND:

THE TRADE AND DEVELOPMENT ACT OF 2000 ("THE ACT"), WAS SIGNED INTO LAW
ON MAY 18, 2000. TITLE II OF THE ACT CONCERNS TRADE BENEFITS FOR THE
CARIBBEAN BASIN AND IS REFERRED TO IN THE ACT AS THE "UNITED STATES-
CARIBBEAN BASIN TRADE PARTNERSHIP ACT" (THE CBTPA).

PRESIDENTIAL PROCLAMATION 7351 IMPLEMENTED THE CBTPA AND DESIGNATED
ELIGIBLE COUNTRIES AND HARMONIZED TARIFF SCHEDULE (HTS) ITEM NUMBERS.
PROCLAMATION 7351 WAS SIGNED ON OCTOBER 2, 2000, AND WAS PUBLISHED IN
THE FEDERAL REGISTER ON OCTOBER 4, 2000 (65 FR 59329). PRESIDENTIAL
PROCLAMATION 7388, WHICH IDENTIFIED ADDITIONAL HTS ITEM NUMBERS FOR
WATCHES, WATCH PARTS AND FOOTWEAR, WAS SIGNED ON DECEMBER 18, 2000, AND
PUBLISHED IN THE FEDERAL REGISTER OF DECEMBER 21, 2000 (65 FR 80723).

INTERIM CUSTOMS REGULATIONS (NEW 19 CFR 10.231 THROUGH 10.237) IMPLE-
MENTING THE TRADE BENEFIT PROVISIONS OF THE CBTPA WERE PUBLISHED IN
THE FEDERAL REGISTER ON OCTOBER 5, 2000 (65 FR 59650).

TITLE II OF THE ACT AMENDS THE CARIBBEAN BASIN ECONOMIC RECOVERY ACT
(CBERA), WHICH IS CODIFIED AT 19 USC 2701 THROUGH 2707, TO PROVIDE
ADDITIONAL TRADE BENEFITS TO CERTAIN DESIGNATED BENEFICIARY COUNTRIES.
THE AMENDMENT TO CBERA PROVIDES FOR PREFERENTIAL TARIFF TREATMENT FOR
TEXTILE AND APPAREL ARTICLES, AS WELL AS "NORTH AMERICAN FREE TRADE
AGREEMENT (NAFTA) PARITY" TREATMENT OF NON-TEXTILE GOODS PREVIOUSLY
EXCLUDED FROM CBERA ELIGIBILITY.

THIS MEMORANDUM CONCERNS ONLY THE NAFTA PARITY PROVISIONS FOUND IN
SECTION 211 OF THE CBTPA.

NON-TEXTILE ARTICLES ELIGIBLE FOR NAFTA PARITY TREATMENT:

IN REGARD TO NON-TEXTILE GOODS, SECTION 211 AMENDS 19 USC 2703(B) BY
PROVIDING TARIFF TREATMENT IDENTICAL TO THAT AFFORDED GOODS OF MEXICO
UNDER NAFTA FOR THE FOLLOWING GOODS IF THEY QUALIFY AS CBTPA ORIGINA-
TING GOODS AND ARE IMPORTED DIRECTLY INTO THE UNITED STATES FROM A
CBPTA NBENEFICIARY COUNTRY ("IMPORTED DIRECTLY" IS DEFINED AT 19 CFR
10.233(D)):

* FOOTWEAR NOT DESIGNATED ON AUGUST 5, 1983, AS ELIGIBLE ARTICLES FOR
THE GENERALIZED SYSTEM OF PREFERENCES;

* TUNA, PREPARED OR PRESERVED IN ANY MANNER, IN AIRTIGHT CONTAINERS;

* PETROLEUM, OR ANY PRODUCT DERIVED THEREFROM, PROVIDED FOR IN HEADINGS
2709 AND 2710 OF THE HARMONIZED TARIFF SCHEDULE OF THE UNITED STATES
(HTS);

* WATCHES AND WATCH PARTS (INCLUDING CASES, BRACELETS AND STRAPS), OF
WHATEVER TYPE INCLUDING, BUT NOT LIMITED TO, MECHANICAL, QUARTZ DIGITAL
OR QUARTZ ANALOG, IF THOSE WATCHES OR WATCH PARTS CONTAIN ANY MATERIAL
WHICH IS THE PRODUCT OF ANY COUNTRY WITH RESPECT TO WHICH HTS COLUMN 2
RATES OF DUTY APPLY; OR

* ARTICLES TO WHICH REDUCED RATES OF DUTY APPLY UNDER 19 USC 2703(H)
(I.E., CERTAIN HANDBAGS, LUGGAGE, FLAT GOODS, WORK GLOVES AND LEATHER
WEARING APPAREL). FOR THESE PRODUCTS, THE AMENDMENTS TO 19 USC 2703(B)
PROVIDE THAT THE APPLICABLE DUTY RATE WILL BE THE LOWER RATE OF DUTY,
WHETHER IT IS DERIVED FROM 19 USC 2703(H) OR THE NAFTA PARITY PROVISIONS
OF THE NEW 19 USC 2703(B)(3)(A).

SECTION 211 DOES NOT PROVIDE FOR SUCH NAFTA PARITY TREATMENT FOR
ARTICLES ACCORDED DUTY-FREE TREATMENT UNDER US. NOTE 2(B) TO SUBCHAPTER
II OF CHAPTER 98, HTS. THIS NOTE CONCERNS CERTAIN ARTICLES ASSEMBLED
OR PROCESSED IN A CBI BENEFICIARY COUNTRY IN WHOLE OF COMPONENTS
OR INGREDIENTS THAT ARE PRODUCTS OF THE UNITED STATES.

THE ANNEXES TO PRESIDENTIAL PROCLAMATIONS 7351 AND 7388 IDENTIFY THOSE
HTS ITEM NUMBERS THAT ARE ELIGIBLE FOR CBTPA PREFERENTIAL TARIFF
TREATMENT AS PER SECTION 211, IDENTIFIED ABOVE. THE RELEVANT PORTIONS
OF THE ANNEXES ARE INCLUDED AS ATTACHMENTS A AND B.

CBTPA ORIGIN RULES:

THE ACT DEFINES A "CBTPA ORIGINATING GOOD" AS ONE THAT MEETS THE RULES
OF ORIGIN FOR A GOOD SET FORTH IN CHAPTER 4 (RULES OF ORIGIN) OF THE
NAFTA AS IMPLEMENTED PURSUANT TO U.S. LAW (SEE GENERAL NOTE 12, HTS OR
19 CFR 181, APPENDIX). THE FOLLOWING CRITERIA SHALL BE USED TO
DETERMINE IF A GOOD ORIGINATES IN THE TERRITORY OF A PARTY. THE
CORRESPONDING LETTER MUST APPEAR IN FIELD 7 OF THE CERTIFICATE OF
ORIGIN DISCUSSED LATER IN THIS MEMORANDUM:

* A - THE GOOD IS "WHOLLY OBTAINED OR PRODUCED ENTIRELY" IN THE
TERRITORY OF ONE OR MORE OF THE CBTPA COUNTRIES.

* B - THE GOOD CONTAINS SOME NON-ORIGINATING MATERIALS, IS PRODUCED
ENTIRELY IN THE TERRITORY OF ONE OR MORE OF THE CBTPA COUNTRIES AND
SATISFIES THE SPECIFIC RULE OF ORIGIN, SET OUT IN NAFTA ANNEX 401, THAT
APPLIES TO ITS TARIFF CLASSIFICATION.

* C - THE GOOD IS PRODUCED ENTIRELY IN THE TERRITORY OF ONE OR MORE OF
THE CBTPA COUNTRIES EXCLUSIVELY FROM ORIGINATING MATERIALS. ALL
MATERIALS USED IN THE PRODUCTION OF THE GOOD MUST QUALIFY AS
"ORIGINATING" BY MEETING PREFERENCE CRITERIA A-D.

* D - GOODS ARE PRODUCED IN THE TERRITORY OF ONE OR MORE OF THE CBTPA
COUNTRIES BUT DO NOT MEET THE APPLICABLE RULE OF ORIGIN, SET OUT IN
NAFTA ANNEX 401, BECAUSE CERTAIN NON-ORIGINATING MATERIALS DO NOT
UNDERGO THE REQUIRED CHANGE IN TARIFF CLASSIFICATION. THE GOODS DO
NONETHELESS MEET THE REGIONAL VALUE-CONTENT REQUIREMENT SPECIFIED IN
NAFTA ARTICLE 401(D). THIS CRITERION IS LIMITED TO THE FOLLOWING
CIRCUMSTANCES:

* THE GOOD WAS IMPORTED IN THE TERRITORY OF A CBTPA COUNTRY IN AN
UNASSEMBLED OR DISASSEMBLED FORM BUT WAS CLASSIFIED AS AN ASSEMBLED
GOOD, PURSUANT TO HARMONIZED SYSTEM (HS) GENERAL RULE OF INTERPRETATION
2(A); OR

* THE GOOD INCORPORATED ONE OR MORE NON-ORIGINATING MATERIALS, PROVIDED
FOR AS PARTS UNDER THE HS, WHICH COULD NOT UNDERGO A CHANGE IN TARIFF
CLASSIFICATION BECAUSE THE HEADING PROVIDED FOR BOTH THE GOOD AND ITS
PARTS AND WAS NOT FURTHER DIVIDED INTO SUBHEADINGS, OR THE SUBHEADING
PROVIDED FOR BOTH THE GOOD AND ITS PARTS.

THE ACT GOES ON TO SET THE FOLLOWING RULES FOR APPLYING NAFTA CHAPTER 4
TO A CBTPA BENEFICIARY COUNTRY:

* ONLY THE UNITED STATES AND A CBTPA BENEFICIARY COUNTRY MAY BE TREATED
AS BEING A PARTY TO THE NAFTA;

* ANY REFERENCE TO TRADE BETWEEN THE UNITED STATES AND MEXICO WILL BE
DEEMED TO REFER TO TRADE BETWEEN THE UNITED STATES AND A CBTPA
BENEFICIARY COUNTRY;

* ANY REFERENCE TO A PARTY WILL BE DEEMED TO REFER TO A CBTPA
BENEFICIARY COUNTRY OR THE UNITED STATES; AND

* ANY REFERENCE TO PARTIES WILL BE DEEMED TO REFER TO ANY COMBINATION
OF CBTPA BENEFICIARY COUNTRIES OR TO THE UNITED STATES AND ONE OR MORE
CBTPA BENEFICIARY COUNTRIES.

CBTPA BENEFICIARY COUNTRIES:

THE CBTPA DEFINES A "CBTPA BENEFICIARY COUNTRY" AS ANY CBERA
BENEFICIARY COUNTRY THAT THE PRESIDENT ALSO DESIGNATES
AS A BENEFICIARY COUNTRY FOR PURPOSES OF PREFERENTIAL
TARIFF TREATMENT UNDER 19USC 2703(B)(3).

PRESIDENTIAL PROCLAMATION 7351 DESIGNATED THE FOLLOWING COUNTRIES AND
TERRITORIES AS CBTPA BENEFICIARY COUNTRIES:

ANTIGUA AND BARBUDA HAITI
ARUBA HONDURAS
BAHAMAS JAMAICA
BARBADOS MONTSERRAT
BELIZE NETHERLANDS ANTILLES
COSTA RICA NICARAGUA
DOMINICA PANAMA
DOMINICAN REPUBLIC ST. KITTS AND NEVIS
EL SALVADOR SAINT LUCIA
GRENADA SAINT VINCENT AND THE GRENADINES
GUATEMALA TRINIDAD AND TOBAGO
GUYANA BRITISH VIRGIN ISLANDS

IN ADDITION TO THE DESIGNATION OF CBTPA BENEFICIARY COUNTRIES, THE
UNITED STATES TRADE REPRESENTATIVE (USTR) MUST ALSO DETERMINE THAT A
COUNTRY HAS IMPLEMENTED AND FOLLOWS, OR IS MAKING SUBSTANTIAL PROGRESS
TOWARD IMPLEMENTING AND FOLLOWING, PROCEDURES AND REQUIREMENTS SIMILAR
TO THOSE INCLUDED IN CHAPTER 5 (CUSTOMS PROCEDURES) OF THE NAFTA. ONLY
AFTER SUCH DETERMINATION HAS BEEN ISSUED WILL PRODUCTS OF A CBTPA
BENEFICIARY COUNTRY BE ELIGIBLE TO RECEIVE PREFERENTIAL TARIFF
TREATMENT.

IN A NOTICE PUBLISHED IN THE FEDERAL REGISTER OF OCTOBER 10, 2000 (65 FR
60236), THE USTR DETERMINED THAT THE FOLLOWING 10 COUNTRIES HAVE
IMPLEMENTED AND FOLLOW, OR ARE MAKING SUBSTANTIAL PROGRESS TOWARD
IMPLEMENTING AND FOLLOWING, THE PROCEDURES AND REQUIREMENTS DESCRIBED
ABOVE. ARTICLES FROM THESE COUNTRIES ENTERED, OR WITHDRAWN FROM
WAREHOUSE FOR CONSUMPTION, ON OR AFTER OCTOBER 2, 2000, ARE ELIGIBLE TO
RECEIVE CBTPA PREFERENTIAL TARIFF TREATMENT:

BELIZE HAITI
COSTA RICA HONDURAS
DOMINICAN REPUBLIC JAMAICA
EL SALVADOR NICARAGUA
GUATEMALA PANAMA

THE USTR ISSUED A SECOND DETERMINATION, PUBLISHED IN THE FEDERAL
REGISTER OF NOVEMBER 21, 2000 (65 FR 69988), IN WHICH GUYANA WAS FOUND
TO BE MEETING THE NECESSARY REQUIREMENTS. ARTICLES FROM GUYANA ENTERED,
OR WITHDRAWN FROM WAREHOUSE FOR CONSUMPTION, ON OR AFTER NOVEMBER 9,
2000, ARE ELIGIBLE TO RECEIVE CBTPA PREFERENTIAL TARIFF TREATMENT.

IN THE FUTURE, THE USTR MAY ISSUE ADDITIONAL DETERMINATIONS REGARDING
THE ELIGIBILITY OF OTHER CARIBBEAN NATIONS TO RECEIVE CBTPA
PREFERENTIAL TARIFF TREATMENT.

CERTIFICATE OF ORIGIN:

THE CBTPA CERTIFICATE OF ORIGIN MUST BE USED TO CERTIFY THAT AN ARTICLE
QUALIFIES FOR CBTPA PREFERENTIAL TARIFF TREATMENT. THE EXPORTER IN THE
CBTPA BENEFICIARY COUNTRY MUST PREPARE THE CBTPA CERTIFICATE OF ORIGIN.
IF THE EXPORTER IS NOT THE PRODUCER OF THE ARTICLE, THE EXPORTER MAY
COMPLETE A CBTPA CERTIFICATE OF ORIGIN ON THE BASIS OF (A) ITS
REASONABLE RELIANCE ON THE PRODUCER'S WRITTEN REPRESENTATION THAT THE
ARTICLE QUALIFIES FOR PREFERENTIAL TARIFF TREATMENT OR (B) A COMPLETED
AND SIGNED CBTPA CERTIFICATE OF ORIGIN FOR THE ARTICLE VOLUNTARILY
PROVIDED TO THE EXPORTER BY THE PRODUCER.

CUSTOMS FORM (CF) 450, THE CBTPA NON-TEXTILE CERTIFICATE OF ORIGIN, IS
NOT YET AVAILABLE FOR USE. UNTIL SUCH TIME AS THE OFFICIALLY PRINTED
VERSION OF THE FORM IS AVAILABLE, EXPORTERS MAY USE A DRAFT COPY OF THE
CERTIFICATE THAT IS INCLUDED AS ATTACHMENT C. FURTHER NOTIFICATION
WILL BE PROVIDED WHEN THE CF 450 IS READY FOR USE.

IMPORTER REQUIREMENTS:

THE IMPORTER MUST MAKE A WRITTEN DECLARATION THAT THE ARTICLE QUALIFIES
FOR CBTPA PREFERENTIAL TARIFF TREATMENT. THIS DECLARATION SHALL BE MADE
AT THE TIME OF FILING THE ENTRY SUMMARY BY PLACING ON THE DOCUMENT THE
SPECIAL PROGRAM INDICATOR (SPI) "R" AS A PREFIX TO THE HTSUS SUBHEADING
NUMBER FOR EACH ARTICLE FOR WHICH SUCH TREATMENT IS CLAIMED. WITH
CERTAIN EXCEPTIONS, THE DECLARATION MUST BE BASED ON A COMPLETE AND
PROPERLY EXECUTED CERTIFICATE OF ORIGIN THAT COVERS THE ARTICLE BEING
IMPORTED. SUCH CERTIFICATE OF ORIGIN, OR A COPY THEREOF, MUST BE IN THE
IMPORTER'S POSSESSION AT THE TIME THAT THE CLAIM IS MADE (SEE 19 CFR
10.235).

THE CERTIFICATE OF ORIGIN DESCRIBED IN THE ABOVE PARAGRAPH WILL NOT BE
REQUIRED IN THE FOLLOWING INSTANCES:

* THE PORT DIRECTOR HAS, IN WRITING, WAIVED THE CERTIFICATE OF ORIGIN
REQUIREMENT BECAUSE S/HE IS OTHERWISE SATISFIED THAT THE ARTICLE
QUALIFIES FOR PREFERENTIAL TARIFF TREATMENT;

* THE ARTICLE IS SUBJECT TO A NON-COMMERCIAL IMPORTATION; OR,

* THE ARTICLE IS SUBJECT TO A COMMERCIAL IMPORTATION, THE ARTICLE'S
VALUE DOES NOT EXCEED $2,500, AND THE IMPORTER OR AUTHORIZED AGENT
INCLUDES THE STATEMENT DESCRIBED IN 19 CFR 10.236(D)(III) ON OR WITH
THE INVOICE.

EACH IMPORTER CLAIMING CBTPA PREFERENTIAL TARIFF TREATMENT MUST
MAINTAIN, IN THE UNITED STATES, ALL RECORDS RELATING TO THE IMPORTATION
OF THE ARTICLE. THOSE RECORDS MUST INCLUDE THE ORIGINAL CERTIFICATE OF
ORIGIN AND ANY OTHER RELEVANT DOCUMENTS OR RECORDS AS SPECIFIED IN 19
CFR 163.1(A). AN IMPORTER WHO CLAIMS CBTPA PREFERENTIAL TARIFF
TREATMENT MUST PROVIDE, WITHIN 30 DAYS OF A REQUEST FROM THE PORT
DIRECTOR, A COPY OF THE CERTIFICATE OF ORIGIN PERTAINING TO THE ARTICLE.
COMPLETE REQUIREMENTS FOR THE CERTIFICATE OF ORIGIN TO BE SUBMITTED TO
CUSTOMS ARE FOUND AT 19 CFR 10.237(B).

IF THE PORT DIRECTOR DETERMINES THAT A CERTIFICATE OF ORIGIN IS
ILLEGIBLE, DEFECTIVE, OR HAS NOT BEEN COMPLETED IN ACCORDANCE WITH 19
CFR 10.237(B), THE IMPORTER WILL BE GIVEN NOT LESS THAN 5 WORKING DAYS
TO SUBMIT A CORRECTED CERTIFICATE. FAILURE TO PROVIDE A VALID
CERTIFICATE OF ORIGIN TO CUSTOMS UPON REQUEST WILL RESULT IN THE DENIAL
OF THE CBTPA CLAIM.

THE CERTIFICATE OF ORIGIN, AS DESCRIBED AT 19 CFR 10.237(B), MAY BE FOR
A SINGLE IMPORTATION OR FOR MULTIPLE IMPORTS OF IDENTICAL ARTICLES THAT
OCCUR WITHIN A SPECIFIED PERIOD, NOT TO EXCEED 12 MONTHS (A "BLANKET"
CERTIFICATE). THE EXPORTER MUST SPECIFY THE PERIOD OF VALIDITY ON ANY
BLANKET CERTIFICATES OF ORIGIN. IF THE PORT DIRECTOR DETERMINES THAT AN
IMPORTED ARTICLE COVERED BY A BLANKET CERTIFICATE DOES NOT QUALIFY FOR
PREFERENTIAL TARIFF TREATMENT, THE CERTIFICATE OF ORIGIN CANNOT BE
APPLIED TO SUBSEQUENT IMPORTS DURING THE BLANKET PERIOD.

CERTAIN ARTICLES, SUCH AS LEATHER GOODS, MAY BE INCLUDED IN THE REDUCED
DUTY PROVISIONS OF BOTH THE CBERA AND CBTPA. IF, UPON REVIEWING THE
NAFTA RULES OF ORIGIN AND DETERMINING THAT SUCH AN ARTICLE QUALIFIES AS
A CBTPA ORIGINATING GOOD, AND ALSO QUALIFIES FOR CBERA REDUCED DUTY
UNDER 19CFR 10.198A, THE IMPORTER IS ENTITLED TO CLAIM THE LOWER OF THE
CBTPA PARITY RATE OF DUTY OR THE CBERA REDUCED RATE OF DUTY. IF THE
ARTICLE DOES NOT QUALIFY AS A CBTPA ORIGINATING GOOD BASED ON THE NAFTA
RULES OF ORIGIN, THE IMPORTER MAY STILL CLAIM THE REDUCED CBERA RATE OF
DUTY ON THE ARTICLE SO LONG AS IT QUALIFIES FOR SUCH TREATMENT UNDER 19
CFR 10.198A.

VERIFICATIONS OF CLAIMS:

A CLAIM FOR CBTPA NON-TEXTILE PREFERENTIAL TARIFF TREATMENT WILL BE
SUBJECT TO WHATEVER VERIFICATION THE PORT DIRECTOR DEEMS NECESSARY. ANY
SUCH VERIFICATION WILL BE CONDUCTED AGAINST THE IMPORTER. THIS IS A KEY
DIFFERENCE FROM NAFTA,WHICH GENERALLY SERVES AS THE MODEL FOR THE CBTPA
NON-TEXTILE PROGRAM. NAFTA VERIFICATIONS ARE CONDUCTED AGAINST THE
EXPORTER IN A FOREIGN COUNTRY. IF, FOR ANY REASON, THE PORT DIRECTOR
IF PREVENTED FROM VERIFYING THE CLAIM, S/HE MAY DENY THE CLAIM FOR
PREFERENTIAL TARIFF TREATMENT (SEE 19 CFR 10.237).

ACTION:

EFFECTIVE IMMEDIATELY, IMPORTERS MAY FILE CLAIMS FOR PREFERENTIALTARIFF
TREATMENT OF CBTPA ORIGINATING NON-TEXTILE GOODS FROM THOSE CBTPA
BENEFICIARY COUNTRIES FOR WHICH A POSITIVE USTR DETERMINATION HAS BEEN
ISSUED. IN ADDITION, IMPORTERS OR THEIR AGENTS MAY AVAIL THEMSELVES OF
ALL AVAILABLE POST-ENTRY PROCEDURES, WITH THE EXCEPTION OF NAFTA 520(D)
CLAIMS, TO RECEIVE A REFUND OF DUTIES FOR ELIGIBLE CBTPA NON-TEXTILE
ARTICLES ENTERED, OR WITHDRAWN FROM WAREHOUSE FOR CONSUMPTION ON OR
AFTER THE EFFECTIVE DATE OF THE USTR DETERMINATION.

AS OF THE WRITING OF THESE INSTRUCTIONS, THE AUTOMATED COMMERCIAL SYSTEM
(ACS) HAS NOT BEEN UPDATED TO ALLOW FOR AUTOMATED PROCESSING OF THESE
ENTRIES. UNTIL FURTHER NOTICE FROM THE OFFICE OF TRADE PROGRAMS AT
CUSTOMS HEADQUARTERS, IMPORTERS CLAIMING NAFTA PARITY TREATMENT UNDER
THE CBTPA MUST FILE THEIR ENTRIES MANUALLY.

QUESTIONS REGARDING THE NON-TEXTILE PROVISIONS OF THE CBTPA SHOULD BE
DIRECTED TO LEON HAYWARD, TRADE AGREEMENTS BRANCH, AT (202) 927-9704.

/S/
PAUL K. SCHWARTZ, FOR
ELIZABETH G. DURANT

ATTACHMENTS (3) (PLEASE CONTACT YOUR LOCAL PORT OF ENTRY OR LEON
HAYWARD FOR COPIES OF THE ATTACHMENTS.)

CC: EXECUTIVE DIRECTOR, FIELD OPERATIONS