Unlock the Power of eSignature Lawfulness for Export in United States

How to eSign a document: e-signature lawfulness for Export in United States

good afternoon ladies and gentlemen thank you and Welcome to our briefing today itar for government contractors developments under export control reform I'm Tom McVey with the law firm of Williams Mullen here in Washington DC um at the outset we'd like to thank our friends at NC the National Association of government contractors this is a great organization these are great resources that they provide um and um you all are quite fortunate to have a group like this behind you so uh hopefully you'll take full advantage of everything that they provide um our agenda here is uh pretty straightforward um part one I'm going to take just a few minutes to go through some of the basic principles of itar and E uh just as a little refresher um we want to get people on the same page um you really need to know those some of the basics in order to understand the the changes uh and then part two of course we'll get into a very detailed review of uh export control reform um what we're going to do is I'm going to go through the PowerPoint slides um at the end of the presentation we will send copies of the slides to everyone um in addition there is a chat feature in the program and parties participants will be able to ask questions uh questions are important I really think they're a vital part of the presentation so I encourage you to submit them um I may be able to answer questions during the presentation um but I definitely will be able to answer them at the end so um type in the questions if you go to the bar it'll in the upper left it'll say show chat and then it'll say chat with presenter and you just hit the send button so um all right and the uh there's really three areas of export control laws we're only going to have time to discuss the first two itar and e um but you really can't mention export controls without at least um mentioning that there's this third area we're not going to have time to go into it the ofac sanctions laws but if anyone has any questions uh regarding how that fits into what we're discussing I'll be glad to discuss questions all right so let's get into part one an overview of the basic principles um itar stands for international traffic in arms regulations it's administered by the directorate of Defense trade controls within the state department and the purpose of these Rags are are to to regulate military products um now this often overlaps with commercial products and that can be confusing uh in some cases so we I'll be explaining how to deal with that but itar is design intend intended for military product uh export Administration regulations are intended for commercial product so under itar administered by the state department the Department of Defense is also very heavily involved uh in administering itar ditsa the defense technology Security Administration and other DOD program offices in fact if you send a case over to the state department they'll almost immediately send it over to the Department of Defense so this is actually regulation by the defense department uh in in very great part all right the first Cornerstone concept under itar is itar contains a list of products it's called the US Munitions list and if your product is on the list you're subject to these controls this is a basic concept that flows through through out uh this list by the way that I just had up is not a complete list of all the items it's just sort of the table of content um all right another big piece of this is technical data uh and software so if you have a product on the list let's say it's a navigational device uh software that's used to run that item is also on the list and Technical dat data regarding that product is also on the list technical data drawings algorithms manuals uh any information on the design manufacturer or use of the item um so if an item is on the list the electronic files are on the list uh specification sheets the technical manuals the formulas um all of the sort of information that flows with that as well and the question comes up of course how does one export software and Technical data uh these intangible types of exports well the state department has a very broad uh definition of how one exports these items um if you send it abroad if you take the disc and put it in the FedEx and send it over to to the UK that's the export of technical data if you go abroad and release it if you give a presentation to a business group a private meeting uh or even a private conversation with the foreign National overseas that's the export of technical data even just bringing it with you and not releasing it just keeping it in your laptop if you travel overseas uh is an export of technical data electronic Transmissions with foreign Nationals so sending an email or a fax or a phone call with a foreign National um is the export of technical data and most significantly if a foreign National comes to the United States and has access to the technical data here that's considered an export to his home his or her home country so um this is what's called the deemed export rule uh if you disclose technical data to a foreign party in the US that's considered an export as well um there's a case um in California called the suntech microwave case which was the first criminal conviction um under the deemed export rule a few years back uh in that instance a company was doing work on control technical data disclosed some of that to um a Chinese National who was working in the lab in the United States and that was a violation um the first criminal conviction uh under the deemed export rules the um a question that comes up of course that's very important is what exactly is a foreign National let me pull that back for a second um what exactly is a foreign National um if if a foreign person is in the United States and they have permanent resident alien status they're treated as if they're a a US citizen under the export control laws um if they're here in the United States and they don't have a permanent resident alien status um they're treated as if they're a foreign person permanent resident alien status is a green card so if the person has a green card they're treated as if they're a US citizen um if they don't if they're here on a Visa a business Visa L1 H1B student visa they're treated as a foreign person okay um another key component here is Services If an item is on the mici's list performing uh services for a foreign party related to that item is also regulated it's also on the list and regulated so let's stick with our example of a navigational device um if the device is on the list performing services related to that device for a foreign party is subject to itar installation services troubleshooting Services warranty repair services um these are subject to those controls Engineering Services retrofitting Consulting uh Services Etc here's some examples of us Munitions list items this is not a complete list um now I will tell you a number of these are being transferred over to the Commerce Department to the Commerce control list under export control reform and we'll be discussing that in further detail in just a couple of minutes so um that's part of uh the export control reform um some other examples of items on the US Munitions list um this is category 11 A6 um computers designed or modified Prov for military use um this is an example of what's called a catchall under itar and a catchall is a sort of very broad open um category description it's not specific it's not technical it's all encompassing um 11 A6 is currently um under uh relates to computers and electronics this will be changed under under export control reform this provision will be transferred over to the Commerce Department uh but it's still in effect as of as of right now um and one of the things to note about these is let me just step back here um these categories are a bit misleading um the category is really just the table of contents so Category 6 Naval vessels well well Naval vessels are on the Munitions list but also often included on these categories are all of the uh mission systems and components and attachments that are included as part of that so in addition to the ship itself you may also have the electronics on the ship um the communications gear the navigation system the computer system the training equipment the high performance materials used Us in parts of the vessel um so you you picture not just the end product but many of the items as well all right another example um often intelligence and security products uh and services are covered um a lot of a company may say well itar regulates military products right but we do intelligence Services we perform intelligence activities for the US government that's not military well as you'll see here um intelligence and security uh is sprinkled in different places throughout the usml and in some instances such like such activities could be included as part of the US Munitions list um and parts and components are often included um both in the old version of these RS and in the new version uh in the new version of the regs um they're coming out with a definition of the term specially designed um and this will uh be used to help identify which parts and components are included but as we move forward uh if the naval vessel uh is on the list and certain mission systems and other systems are on the list in many cases Parts components accessories attachments and software that are specially designed for those items may also be included um on the list um another area that's very important to especially to government contract firms are Services um so I mentioned previously that um um performing a service related to an item on the usml is regulated well in addition there's some other standard loan services that also are regulated so performing a military advice providing military advice to a foreign party is regulated uh military military training for foreign military um is uh covered on the list other training of us ml items um a question we see a lot from clients is um the the company is hired by the US military by the Army to train foreign forces um we we the Army hires them to train some British military or Australian military and the training might be overseas it might be in the United States um um since they're performing a service for a foreign party that's on the munition list and they require a technical assistance agreement or a TAA and that's even if the customer paying for it is the US government is the US Army um so services are a big part of this a key uh question that um Regulators at the state department will ask um if they're trying to determine if something's on the mici's list or not is was this developed with Government funding any government sponsored research DOD funding sbir contracts or things of that nature if if there's DOD funding involved there's it's considered a high likelihood um that the item will be on the Munitions list it's not 100% certain sometimes it's not but in many cases it is so if anyone is performing work using um particularly Department of Defense funding um there's a significant chance the resulting um products or technology develop could be subject um uh could be on itar subject to uh the mition list requirements this is a also big area for universities that do um research using DOD funding for certain types of uh applied research uh other examples of usml classified information uh classified products and Technical data uh is on the the Munitions list uh category 17 so if you're doing any uh classified work for your government customers um that automatically subjects You2 itar by virtue of that activity um now there's a process um often parties are trying to determine if their product or their service uh is is on the Munitions list and in many cases it's hard to tell um so the state department has a process called a commodity jurisdiction request and under the process you send in a question you you send in information about your product to the state department provide certain types of information and they will tell you in writing if the item is on the Munitions list or not so this is a very valuable process as it gives you legal certainty with regard to some of these issues that are sometimes quite gray the only thing I would suggest is um we recommend that you don't just send in information about your product and say am I on the list um what we recommend is you provide very specific information um that addresses the standard of the law there's a standard of the law regarding what is on the list and what is not and we recommend providing detailed information about why you feel it should not be on the list uh address the legal standards provide evidence of that position um you want to provide sales data with regard to your product provide other types of evidence to support your position um don't just send it in and say are we on the list it's it's usually better to send it in and say we think it should not be on the list and here's the reasons why and here's the evidence to support our statements um this is probably one of the most important things that we do for our clients um is submit commodity jurisdiction requests so um all right let's see all right so let's say your product is on the Munitions list uh what does that mean what are the requirements up to now we're just worried about my on the list or not so let's say we're on the list what requirements flow from that well number one if for physical products if it's on the list you're not permitted to export it out of the UN unless you have an export license physical products can't export without a license for technical data and software you're not permit to export it out of the United States without a license and you're not permitted to disclose it to foreign Nationals in the United States without a license so you can't take it out of the US can't disclose it to foreign parties in the US unless you have a for services you're not permitted to perform Services defense services for foreign parties uh outside the US or inside the US unless you have a license the license for defense Services is called a technical assistance agreement or a TAA so you can't perform services for foreign parties either overseas or in the US without getting a TAA so how do you perform a service for a foreign party in the United States um well a phone call if a foreign company hires you to provide advice to them on how to integrate certain defense equipment into their systems and you're giving advice you're sitting on the phone uh in hearnden Virginia and they're sitting on the phone over in uh the Czech Republic um if you're telling them how to do something that's you're providing a defense service if it's related to a Munitions item um also our Law Firm has an office in norfol we do a lot of work in norfol um and there's a lot of these ship repair companies down there um and foreign Naval vessels come into the port to get retrofitted and often um the US company will be performing services on these foreign neighbor vessels um in many cases that's a defense service you're performing a service for a foreign military party and that's even if it's right here in the United States even if it's right here in norfol Virginia uh also Imports if parties are importing defense items there may be import requirements either under itar or under um regulations by the Bureau of Alcohol Tobacco and Firearms um here's some other requirements under itar we're not going to have time to go into all these um but suffice it to say registration you may be required to file reports on payments of sales commissions broker registration recordkeeping requirements Etc um and if anyone has any questions about these um I'll be glad to answer them the penalties as I've alluded to earlier these are criminal statutes um viol penalties for violations including include um up to 20 years imprisonment or financial penalties of up to $1 million per violation the uh justice department uh can and often will prosecute individuals not just corporations but individuals including officers directors and employees performed in the in the wrongdoing so um another sanction available is the bment and in many cases government contract firms that can be um another very serious uh side effect in terms of um some sort of a penalty um here's some recent cases these are coming out all the time I put them up just as an example they're sort of all over the lot in terms of the types of companies and the types of violations um often in an enforcement case uh another action that the government takes is they put out a press release so the press release goes up and then it's out on the internet and anytime someone Googles your name they run across this press release so that can be a a a big uh issue as well uh about a third of these prosecutions if you look at the Department of Justice um reports on export um prosecutions they have an annual report each year um about a third of these are large companies 2third are midsize or small companies uh and you say well why are they picking on little companies why are we um why prosecute little companies why don't you go after the big ones and and the answer is twofold number one Sometimes some of the most sophisticated technology is being developed by small and midsize companies companies getting sbir contracts doing very uh sophisticated applied research at the very early stages of these Technologies um and so they consider that some of the crown jewel so they want to put as much of a level of control on that early research as the um the work that's done later on in the large program companies the other reason is they don't want small companies to think that they get a get out of jail free card um uh small size companies are subject to the same rules as everyone else so this company here for example Alli tell Us's Labs I never heard of these guys there's a lot of a lot of these Enforcement cases you just never heard of the companies they're small and midsize companies all right if you're subject to these controls what's your plan for complying with them um we recommend a thre prong strategy um classification application compliance program classification simply means you've got to figure out if your product or your service is on the list is on the mition list remember we said if you're on the list we're subject to controls so you've got to go through your products and your services to see if it's subject to the controls um for government contractors uh you're not manufacturing products you're performing services but those Services can be subject to itar we recommend that for every new contract the company services contract uh the company go through the contract in the beginning to determine if there's any itar VI any itar requirements um that will arise in the course of the contract any new contract for an idiq any new task orders any new piece of business or activity review it in advance to see if there's any itar requirements in fact we recommend you actually review at the marketing stage because you could be transferring technical data even before you get the contract uh in marketing proposals or marketing presentations Etc um so classification is important application application simply means if you need a license apply for um a lot of people think if I'm subject to itar um I can't do business overseas or it shuts everything down and the answer is that's that's not correct at all um many companies in the defense industry do robust business overseas you just need to know what the requirements are if you need a license apply for the license uh and then you can do the business the third piece is compliance program a compliance program is simply a management system in your company to comply with the law you you all now uh know what the requirements are under itar CU you went to this program um but there's how do you get the word out to the rest of the people in your company well that's where the compliance program comes in you designate an official in charge of compliance in the company you do your classifications you adopt written policies and procedures um you conduct training for your people this is all part of the compliance program process this is probably uh the second most important thing that we do for our clients is help them adopt compliance programs provide we provide the policies and procedures and conduct the training and help get them up to speed okay I said there's two parts of these export controls one is itar and the other is the export Administration regulations so I'll just mention e for one second so e are is this whole second set of of controls this is administered by the Commerce Department the export Administration regulations is really intended to control commercial products that have some application in the defense uh in defense products so itar is for True defense products e is really for products that are commercial but they also happen to be useful um in the in in the defense application an example is there's a product called a triggered spark gap triggered spark gap this is a device that creates a very hot spark and it's used it was designed and used to blast kidney stones um in medical procedures well the same the same device can be used to detonate a nuclear weapon um it can be used to detonate a nuclear weapon so that item is regulated on under the export Administration regulations it was not developed as a munition it wasn't developed as a weapon it was developed as a milit as a medical product but because it can be handy can come in handy in a military setting uh it's subject to the controls all right the um the export Administration regulations uh have a lot of the same basic concepts as itar they they also have a list of products it's called the Commerce control list all right it's a different list uh if your product is on the list the product may require an export license not all the time depends on the country um so you have to watch that list another requirement is that these rules also apply to software and Technology as well intangibles so many of the rules under the E are fairly similar to itar so here's some examples and you can see these are really commercial products rather than than true military products there's also um a number of requirements under the E that apply um even if your item is not on the Commerce control list we we do not have time to go into these today but just make a note this um and we can talk about it later if anyone has a question um all right so let's get into export control reform part two this is the important part of the program so export control reform started back in 2009 President Obama and Senior Executives were sitting at the senior white house uh exacts were sitting around trying to figure out ways to increase in employment we were in a recession and they wanted to increase jobs and they said well one way to increase jobs is to increase exports and what can we do to help increase exports and one of the things that was recommended was to reduce the burdens created by the export control laws so um these laws this process started way back um 5 years ago um and and they're still underway uh at the outset of this process there was a long list of uh ambitious goals that they wanted to achieve and at the end of the day um they agreed that they were just they will never get everything done so they've reduced the activities that they were aiming for as part of export control reform probably the single most important component of export control reform that's come forward is what I call the rationalizing the the Commerce control the US Munitions list and the Commerce control list and what's happening as part of this process is that officials at the state department and the defense department are going through the US Munitions list and they're revising it they're removing certain items from the list and other items they're defining more precisely uh in more technical terms it's what's called a positive list and this is um and they're they're getting they're going to try to get rid of some of those catchalls if you remember um those broad open-ended descriptions so so that's the good news State and DOD are going through the list they're cleaning it up they're trying to improve it and make it easier for us exporters to work with the bad news is items that are removed from the Munitions list are are not being decontrolled they're not being just thrown away rather those items are being transferred over to the Commerce department and the Commerce department will regulate exports of these items um the items are are being taken off the Munitions list they're being put onto the Commerce control list there's actually a new section of the Commerce control list for these Munitions items it's called this the 600 series so items are being transferred over to Commerce and will be regulated under Commerce um all right so once an item is regulated at Commerce it still will be subject to export licensing requirements you'll still need a license to export the 600 series items to every country except Canada um it still be restricted from going to countries subject to us arms embargos such as China and they'll still be subject to many I would say most of the same types of export restrictions that applied under itar um but there's a few differences there's a few differences that make this a little more flexible for exporters um if an item is regulated at the Commerce Department it's subject to a few more more license exceptions a a little bit more flexible uh exception uh list of exceptions the most significant one is what's called strategic trade authorization where you can export um to certain Allied countries friendly countries uh without a license in certain instances for government and users um you'll be able to take advantage of What's called the Dom Minimus rule for um foreign uh products manufactured overseas um if it if it has below a certain level of us content um the pH product is not subject to us export licensing requirements and there's other some other advantages of being regulated under the e as well so the big picture is it they're cleaning up itar they're taking the items off of vitar but they're not being decontrolled they're sent over to Commerce and they'll be subject to licensing at Commerce all right a big complaint that people had about itar um was it had these these catchalls these open-ended uh categories as I mentioned earlier such as electronic equipment specifically designed for a military youth or something like that and they were throughout the itar all right well many of these catchalls have been removed from the Munitions list um however they're not all being removed and eliminated um many of those catchalls are simply being transferred over to the Commerce Department under the E so here for example on this slide is the new CCO entry for for military Electronics this was taken off of the Munitions list it was transferred over to the Commerce control list and the new CCL entry reads electronic equipment specially designed for a military use so unfortunately you still have this these very broad catchalls except they're showing up over on the Commerce Department list rather than on the state department list this um electronic equipment item here 3611 also applies to radar systems Telecommunications equipment computer equipment specifically designed for military use and it also covers Parts components accessories and attachments specially designed for an item in this category or on the usml so unfortunately despite the efforts to simplify the list these catchalls are still with us they're just sent over to the Commerce Department all right now the important thing is um as these new regulations are coming out um you want to review both the revisions to the US Munitions list as well as the companion revisions to the Commerce control list and we're going to talk some more about that in a second all right here's some more of these catchalls that are over in the Commerce control list all right under the these changes there are still uh many control on Parts components attachments and accessories not all parts and components are are subject to the regulation many of them still are um to help capture this and create a legal definition for this they've begun using the term specially designed all right so you may read for example in category 8f it'll say developmental aircraft and specially designed parts components accessories and attachments all right so they've made great efforts to take this term specially designed and give it a very precise definition and this definition is set out there's a version in itar and a very similar version in the E and I set the definition out here um it's quite technical I'm not going to read it um what I want you to know is that this is this is now part of the law as you review these revised categories and the revised entries you will see this term specially designed um I want you to know that there's a very special definition there and you need to refer to that definition um and I'm going to jump right through that here's a summary that folks that the state department had put together okay so the timing uh these changes are being implemented on a rolling basis um the state department and the defense department are reviewing the the US Munitions list a few categories at a time they they they work on a few and then they'll publish the regulations and they'll work on a few more and then they'll publish the regulations usually what they're doing is they will put out a proposed rule they'll ask for comments they'll consider the comments and then they'll put out a final rule a final regulation and the regulation might cover two or three categories aircraft um and gas turbine engines Etc um when they issue the final rule usually the changes under the rule become effective 6 months later so um they want to give industry six months time uh to get comfortable with the new Provisions so in terms of timing um the very first changes were introduced back in 2013 um category 8 for aircraft and parts and gas tur um 19 gas turbine engines the regulation was issued in April of 2013 and the changes became final in October 2013 so folks involved in aircraft Parts um you've been subject to these rules already and you know what's going on um some of the other categories were introduced over the early part of 2014 the two most significant that have just come out um are satellites uh and electronics Electronics category 11 was just issued the final rig was just issued in July the 1st of 2014 and it will become effective December 30th uh of 2013 2014 so it was issued July 1st 2014 and it becomes effective December 30th 2014 so um the the you have to identify which category applies to you and you've got to look at the new regs and figure out the the effective date for that particular category all right for with the revisions now you would now be required to reclassify your products so if your product was on the Munitions list under under a certain category now that these these changes are rolling out over the over this one-ear period you will need to go back and look at the revised category where where your product is regulated and see if it's still regulated under itar um we we recommend that you look at the new revised reg that's issued by the state department and you issue the new companion rag that goes with it that's issued by the Commerce Department each one of these when state issues a reg Commerce also issues a rag for the CCL and you need to look at both of them together all right this is the procedure for export classification um the government has a very uh strict order that they recommend or that they require the classification go through um first you have to determine if the item is subject to itar uh is it on the mition list if it is then you follow the itar requirements if it's not then you go to determine if it's regulated under the export Administration regulations and the Commerce controller so you have to go to state first see if it's regulated there if not then go to Commerce if you're reviewing it at Commerce under the Commerce control list you're you're now required to review first the 600 series items and what they're calling the 500 series items which are satellites and everything else on the on the Commerce control list um what you should not do what they tell you not to do if you go to the Commerce department and requests a classification request um a Commerce Department classification is not binding on the state department um so if if you want to find out what your classification is under itar you have to go to the state department through a commodity jurisdiction request all right there are some transition procedures that they've published Commerce has um what they call general order number five ddtc has a transition plan and the concept behind this is um as an example if um your your product you have a license under itar if you just received the license let's say last month um and then next month your product is transferred from the mition list over to the Commerce control list your existing license will remain in effect for a 2-year period or until it expires under its own terms so they'll give you a a a grace period uh if you have a license under ddtc and your item is transitioned over they'll let let you continue operate under your license for a period of time typically it's 2-year period now these rules are very technical so don't rely just on this summary you really need to look at the reg precisely to see if if and how these RS apply to your particular commodity all right the last point is uh is simply the steps to take um for getting ready for export compliance um for the export control reform many companies have started this process already really what we recommend is companies adopt a plan you need to have a strategy for how to push through uh this process so the first item is on the list is you're reviewing your classifications you're looking at the new categories that are coming out of the state department look at the the companion regulations coming out of the Commerce department and see if your classifications have been changed or if they stay the same um in doing that you may you may have to go through this specially designed process um to determine um if your parts and components are included if your item does transition over to the Commerce control list there'll be a slightly different set of rules that apply um there's no registration uh over uh at the Commerce Department Services are are different um the dominous rules and the see-through rule the see-through rule from um from itar doesn't apply quite the same um they use the Dom Minimus rule at Commerce Department um so you will need to change your compliance processes um ingly and of course we recommend that you coordinate with parties in your supply chain um people below you and above you primes and subs and um program Partners so that everyone is in concurrence on how the changes affect the products in the in the supply chain all right we're coming to the end of the the summary here um I have we have some time for questions I'll mention just well we have a second here um we have if folks are interested in this presentation we have a pre-recorded version of this webinar which we can make available to you it's um available at no charge I can send you the link and you can then um if you want show it to other people in your in your office um you you you play it at whatever time is convenient and you can have folks other folks can watch it so if you're interested shoot me an email and we I'll send you a link to the to the program um at this point we can uh if anyone has any questions I can uh address them just type them in the chat box one one question that comes up all the time from government contract firms is um we are um we are a US company we don't do any exporting our only customer is the US government um are we still subject to these requirements and the answer is you may very well be particularly if you're in the defense industry um even if you have no exports and even if your only customers the US government you may require to register under iar um if you have itar controlled items you can't disclose them to foreign Nationals in the United States uh if you're performing defense services in the US for foreign parties that's regulated if you're importing brokering um or if you're exporting equipment to a US Government customer overseas in many instances exporting to us customers um you you may be required to obtain an export license for that uh or bringing equipment ta 50 equipment uh often companies bring equipment for their people to be using in deployments overseas and bringing that equipment back into the US um is is um is regulated as well you may need licenses for that so um another question we we don't manufacture products we perform Services um will these changes affect us and the answer is yes defense services are regulated under itar as well um if there's changes in the US ml categories that apply to your services then then the regulation of the services could be changed so um also if you're performing services for foreign parties related to defense items there's ALS there's almost certainly issues involving the transfer of technical data to those foreign parties that may require license so the answer is yes even if you just perform Services you still may be subject to these controls we recommend figuring out which category of the US Munitions list apply to your um Services look at the new RS that are coming out of state and look at the companion Rags that are coming out of commas um and what what is the 500 Series so we we've been talking about the 600 series which is the Munitions items transferred over um the 500 series is used to refer to items um to satellite and spacecraft items so um they're considered to be a fairly high priority on the Commerce control list as well um what what ISX what ISX on the CCL this is a little bit confusing to people on the CCL and the US Munitions list well on the US Munitions list dox means um if a company has an export and it includes both items regulated under itar and items on the Commerce control list you can submit one application to ddtc and license the whole transaction so it it's it's a way of having to avoid going to two agency under the cclx is a little different when they use x in an ecn it refers to Parts components accessories and attachments so it's unfortunately different agencies the two agencies do it differently but that's sort of what it applies to um what is the order of review um as part of these new changes uh both agencies State and commerce have actually um set forth an order that you should that they recommend you follow in doing classifications um the new procedure the order of view for itar is at itar section 121.1mi out copies of the program to everyone and um we appreciate your participating and we hope it was helpful all right thank you very much have a good day