Certain Cold-Rolled Steel Flat Products From the Republic of Korea: Affirmative Final Determinations of Circumvention of the Antidumping Duty and Countervailing Duty Orders, 70934-70937 [2019-27816]

Agencies

• DEPARTMENT OF COMMERCE
• International Trade Administration

[Federal Register Volume 84, Number 247 (Thursday, December 26, 2019)]
[Notices]
[Pages 70934-70937]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-27816]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-580-881, C-580-882]


Certain Cold-Rolled Steel Flat Products From the Republic of 
Korea: Affirmative Final Determinations of Circumvention of the 
Antidumping Duty and Countervailing Duty Orders

AGENCY: Enforcement and Compliance, International Trade Administration, 
Department of Commerce.

SUMMARY: The Department of Commerce (Commerce) determines that imports 
of certain cold-rolled steel flat products (CRS), produced in the 
Socialist Republic of Vietnam (Vietnam) using carbon hot-rolled steel 
(HRS) manufactured in the Republic of Korea (Korea), are circumventing 
the antidumping duty (AD) and countervailing duty (CVD) orders on CRS 
from Korea.

DATES: Applicable December 26, 2019.

FOR FURTHER INFORMATION CONTACT: Tyler Weinhold or Fred Baker, AD/CVD 
Operations, Office VI, Enforcement and Compliance, International Trade 
Administration, U.S. Department of Commerce, 1401 Constitution Avenue 
NW, Washington, DC 20230; telephone: (202) 482-1121 or (202) 482-2924, 
respectively.

SUPPLEMENTARY INFORMATION: 

Background

    On July 10, 2019, Commerce published the Preliminary Determinations 
\1\ of circumvention of the CRS Orders.\2\ A summary of the events that 
occurred since Commerce published the Preliminary Determinations, as 
well as a full discussion of the issues raised by parties for these 
final determinations, may be found in the Issues and Decision 
Memorandum.\3\ The Issues and Decision Memorandum is a public document 
and is on file electronically via Enforcement and Compliance's 
Antidumping and Countervailing Duty Centralized Electronic Service 
System (ACCESS). ACCESS is available to registered users at https://access.trade.gov, and it is available to all parties in the Central 
Records Unit, Room B8024 of the main Commerce building. In addition, a 
complete version of the Issues and Decision Memorandum can be accessed 
directly at https://enforcement.trade.gov/frn/. The signed and 
electronic versions of the Issues and Decision Memorandum are identical 
in content.
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    \1\ Certain Cold-Rolled Steel Flat Products from the Republic of 
Korea: Affirmative Preliminary Determination of Anti-Circumvention 
Inquiries on the Antidumping Duty and Countervailing Duty Orders, 84 
FR 32875 (July 10, 2019) (Preliminary Determinations), and 
accompanying Preliminary Decision Memorandum (Preliminary Decision 
Memorandum).
    \2\ See Certain Cold-Rolled Steel Flat Products from Brazil, 
India, the Republic of Korea, and the United Kingdom: Amended Final 
Affirmative Antidumping Determinations for Brazil and the United 
Kingdom and Antidumping Duty Orders, 81 FR 64432 (September 20, 
2016); see also Certain Cold-Rolled Steel Flat Products from Brazil, 
India, and the Republic of Korea: Amended Final Affirmative 
Countervailing Duty Determination and Countervailing Duty Order (the 
Republic of Korea) and Countervailing Duty Orders (Brazil and 
India), 81 FR 64436 (September 20, 2016) (collectively, CRS Orders).
    \3\ See Memorandum, ``Issues and Decision Memorandum for Anti-
Circumvention Inquiries on the Antidumping Duty and Countervailing 
Duty Orders on Certain Cold-Rolled Steel Flat Products from the 
Republic of Korea,'' dated concurrently with, and hereby adopted by, 
this notice (Issues and Decision Memorandum).
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Scope of the Orders

    The products covered by these orders are certain cold-rolled (cold-
reduced), flat-rolled steel products, whether or not annealed, painted, 
varnished, or coated with plastics or other non-metallic substances. 
For a complete description of the scope of the orders, see the Issues 
and Decision Memorandum.

Scope of the Anti-Circumvention Inquiries

    These anti-circumvention inquiries cover CRS produced in Vietnam 
using HRS substrate manufactured in Korea and subsequently exported 
from Vietnam to the United States (merchandise under consideration). 
These final rulings apply to all shipments of merchandise under 
consideration entered on or after the date of the initiation of these 
inquiries. Importers and exporters of CRS produced in Vietnam using HRS 
manufactured in Vietnam or third countries, and who qualify to 
participate in the certification process, must certify that the HRS 
processed into CRS in Vietnam did not originate in Korea, as provided 
for in the certifications attached to this Federal Register notice. 
Otherwise, their merchandise may be subject to antidumping and 
countervailing duties.

Methodology

    Commerce is conducting these anti-circumvention inquiries in 
accordance with section 781(b) of the Tariff Act of 1930, as amended 
(the Act). Because Vietnam is a non-market economy country within the 
meaning of section 771(18) of the Act, Commerce calculated the value of 
certain processing and merchandise using factors of production and 
market economy values, as discussed in section 773(c) of the Act.\4\ 
See Preliminary Decision Memorandum for a full description of the 
methodology. We have continued to apply this methodology for our final 
determination.
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    \4\ See, e.g., Certain Oil Country Tubular Goods from the 
Socialist Republic of Vietnam: Preliminary Results of Antidumping 
Duty Administrative Review, 81 FR 71071 (October 14, 2016) and 
accompanying Preliminary Decision Memorandum at 3, unchanged in 
Certain Oil Country Tubular Goods from the Socialist Republic of 
Vietnam: Final Results of Antidumping Duty Administrative Review; 
2014-2015, 82 FR 18611 (April 20, 2017).
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Analysis of Comments Received

    All issues raised in the case and rebuttal briefs by parties in 
these inquiries are addressed in the Issues and Decision Memorandum. A 
list of the issues raised is attached to this notice as Appendix I.

Final Affirmative Determinations of Circumvention

    We determine that exports to the United States of CRS produced in 
Vietnam from HRS substrate manufactured in Korea are circumventing the 
CRS Orders. We therefore find it appropriate to determine that this 
merchandise falls within the CRS Orders, and to instruct U.S. Customs 
and Border Protection (CBP) to continue to suspend liquidation of any 
entries of CRS from Vietnam produced using HRS substrate manufactured 
in Korea.

[[Page 70935]]

Continuation of Suspension of Liquidation

    As stated above, Commerce has made an affirmative determination of 
circumvention of the CRS Orders by exports to the United States of CRS 
produced in Vietnam using Korean-origin HRS substrate. This 
circumvention finding applies to CRS produced by any Vietnamese company 
using Korean-origin HRS substrate. In accordance with 19 CFR 
351.225(l)(3), Commerce will direct CBP to continue to suspend 
liquidation and to require a cash deposit of estimated duties on 
unliquidated entries of CRS produced in Vietnam using Korean-origin HRS 
substrate that were entered, or withdrawn from warehouse, for 
consumption on or after August 2, 2018, the date of initiation of these 
anti-circumvention inquiries.\5\
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    \5\ See Certain Cold-Rolled Steel Flat Products from the 
Republic of Korea: Initiation of Anti-Circumvention Inquiries on the 
Antidumping Duty and Countervailing Duty Orders, 83 FR 37790 (August 
2, 2018).
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    The suspension of liquidation and cash deposit instructions will 
remain in effect until further notice. In order to prevent evasion, and 
because the AD and CVD rates established in the CRS China Circumvention 
Final are higher than the rates established for CRS from Korea, 
Commerce will instruct CBP to suspend liquidation and collect cash 
deposits in the following manner.\6\ In the situation where no 
certification regarding the origin of the substrate is maintained for 
an entry, and AD/CVD orders from two countries (China or Korea) 
potentially apply to that entry, Commerce intends to instruct CBP to 
suspend the entry and collect cash deposits at the AD rate established 
for the China-wide entity (199.76 percent) and the China CVD all-others 
rate (256.44 percent), pursuant to the CRS China Circumvention Final. 
In the situation where a certification is maintained for the AD/CVD 
orders on CRS from China (stating that the merchandise was not produced 
from HRS from China), but no other certification is maintained, 
Commerce intends to instruct CBP to suspend the entry and collect cash 
deposits at the AD and CVD all-others rates (i.e., 20.33 percent and 
3.89 percent, respectively) applicable to the AD/CVD orders on CRS from 
Korea.\7\
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    \6\ See Certain Cold-Rolled Steel Flat Products from the 
People's Republic of China: Affirmative Final Determination of 
Circumvention of the Antidumping Duty and Countervailing Duty 
Orders, 83 FR 23891 (May 23, 2018) (CRS China Circumvention Final).
    \7\ See CRS Orders.
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    CRS produced in Vietnam from HRS substrate that is not of Korean-
origin is not subject to these inquiries. Therefore, cash deposits are 
not required for such merchandise. However, CRS produced in Vietnam 
from HRS from China is subject to the AD/CVD orders on CRS from China. 
If an importer imports CRS from Vietnam and claims that the CRS was 
produced from non-Korean HRS substrate, in order not to be subject to 
cash deposit requirements, the importer and exporter are required to 
meet the certification and documentation requirements described in 
Appendix II. Exporters of CRS produced in Vietnam from non-Korean 
origin HRS substrate must prepare and maintain an Exporter 
Certification and documentation supporting the Exporter Certification 
(see Appendix IV). In addition, importers of such CRS must prepare and 
maintain an Importer Certification (see Appendix III) as well as 
documentation supporting the Importer Certification. In addition to the 
Importer Certification, the importer must also maintain a copy of the 
Exporter Certification (see Appendix IV) and relevant supporting 
documentation from its exporter of CRS produced from non-Korean-origin 
HRS substrate.
    For these final determinations, we determine that the following 
companies are not eligible for the certification process: 190 Steel 
Pipe Co. Ltd., Central Vietnam Metal Corp., Hoa Phat Steel Pipe Co., 
POSCO E&C, POSCO SS Vina, POSCO VST, VSC--POSCO Steel Corporation, 
Prima Commodities Co., Southern Steel Sheet Co., Ltd., Tan Thanh Quyen 
Steel Co., Thai Nguyen Iron and Steel Corp., Thong Nhat Flat Steel, Van 
Loi Co. Ltd., Vietnam Germany Steel JSC, Vietnam Steel Corp., Vietnam 
Steel Pipe, Vina Kyoei Steel Ltd., Vinda Iron & Steel Co. Ltd., and 
VNSTEEL--Phu My Flat Steel Co. Accordingly, importers of CRS from 
Vietnam that is produced and/or exported by these ineligible companies 
are similarly ineligible for the certification process with regard to 
those imports. Additionally, exporters are not eligible to certify 
shipments of merchandise produced by the above-listed companies. 
Accordingly, Hoa Phat Group Joint Stock Company and Hoa Phat Steel 
Sheet are not eligible to certify shipments of CRS produced by Hoa Phat 
Steel Pipe Co.\8\
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    \8\ See Issues and Decision Memorandum at Comment 11.
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Notification Regarding Administrative Protective Orders

    This notice will serve as the only reminder to all parties subject 
to administrative protective order (APO) of their responsibility 
concerning the destruction of proprietary information disclosed under 
APO in accordance with 19 CFR 351.305(a)(3). Timely written 
notification of return/destruction of APO materials or conversion to 
judicial protective order is hereby requested. Failure to comply with 
the regulations and the terms of an APO is a sanctionable violation.

Notification to Interested Parties

    These determinations are issued and published in accordance with 
section 781(b) of the Act and 19 CFR 351.225(f).

    Dated: December 13, 2019.
Jeffrey I. Kessler,
Assistant Secretary for Enforcement and Compliance.

Appendix I

List of Topics Discussed in the Issues and Decision Memorandum

I. Summary
II. Background
III. Scope of the Orders
IV. Scope of the Anti-Circumvention Inquiries
V. Changes Since the Preliminary Determination
VI. Statutory Framework
VII. Statutory Analysis
VIII. Discussion of the Issues
    Comment 1: Whether Companies That Did Not Receive Commerce's 
Quantity and Value (Q&V) Questionnaire Should Be Permitted to 
Participate in the Certification Process.
    Comment 2: Whether Commerce Abused Its Discretion in Rejecting 
the Q&V Questionnaire Responses of Certain Companies
    Comment 3: Whether Commerce Should Not Apply AFA to SSSC
    Comment 4: Whether Commerce Lacks Statutory Authority to Apply 
AFA Where Respondents Did Not Deprive Commerce of Information 
Regarding Its Ability to Trace Inputs.
    Comment 5: Whether Commerce's Use of AFA Impermissibly Departs 
Without Explanation from Its Decision in the China Anti-
Circumvention Inquiry
    Comment 6: Whether Precluding Certain Importers and Exporters 
from Participating in the Certification Process is Inappropriate and 
Unfairly Punishes Importers
    Comment 7: Whether Commerce Should Allow Additional Time for 
Completing Certifications for Pre-Preliminary Determination Entries
    Comment 8: Whether a Country-Wide Determination is Justified
    Comment 9: Whether Commerce's Interpretation of Section 781(b) 
of the Act Applies to the CRS Production Process in Vietnam and 
Expands the Scope of the Orders
    Comment 10: Whether Commerce Should Amend the Exporter 
Certification Language to Prevent Funneling

[[Page 70936]]

    Comment 11: Whether to Apply AFA to Certain Vietnamese Producers 
That Are Affiliated with Those That Are Deemed Non-Responsive
    Comment 12: Whether Commerce Should Preclude Companies that 
Failed to Cooperate in Both the CRS from China and CRS from Korea 
Inquiries from Participating in the Certification Regime
    Comment 13: Whether to Apply the Highest of the Petition Rate or 
Investigation Calculated Rate as the Cash Deposit Rate for Non-
Responsive Companies
    Comment 14: Whether POSCO Vietnam's History Demonstrates that It 
Cannot Be Viewed as Circumventing
    Comment 15: Whether POSCO Vietnam's Operations Confirm that the 
Process of Assembly or Completion Is Not Minor or Insignificant
    Comment 16: Analysis of Patterns of Trade
    Comment 17: Whether the Value Added in Vietnam Is Significant
    Comment 18: Whether Commerce Should Rely on AFA to Value POSCO 
Vietnam's Scrap Offset
    Comment 19: Whether Commerce Should Account for POSCO Vietnam's 
Failure to Disclose Corporate Affiliations in Its Final 
Determination
IX. Recommendation

Appendix II

Certification Requirements

    If an importer imports certain cold-rolled steel flat products 
(CRS) from the Socialist Republic of Vietnam (Vietnam) and claims 
that the CRS was not produced from hot-rolled steel substrate 
(substrate) manufactured in Korea, the importer is required to 
complete and maintain the importer certification attached hereto as 
Appendix III and all supporting documentation. Where the importer 
uses a broker to facilitate the entry process, it should obtain the 
entry number from the broker. Agents of the importer, such as 
brokers, however, are not permitted to make this certification on 
behalf of the importer.
    The exporter is required to complete and maintain the exporter 
certification, attached as Appendix IV, and is further required to 
provide the importer a copy of that certification and all supporting 
documentation.
    As discussed in the Issues and Decisions Memorandum, for these 
final determinations, we are extending the period for completing 
certifications for shipments and/or entries during the August 2, 
2018 through July 18, 2019 period established in the Preliminary 
Determinations. Accordingly, for shipments and/or entries on or 
after August 2, 2018 through July 18, 2019 for which certifications 
are required, importers and exporters should complete the required 
certification within 30 days of the publication of these final 
determinations notice in the Federal Register.
    For companies that were not eligible to certify pursuant to the 
Preliminary Determinations, but are now eligible pursuant to the 
final determinations, we are also extending the period for 
completion of their certifications for shipments and/or entries from 
August 2, 2018 through the date of Federal Register publication of 
the final determinations until 30 days after publication of these 
determinations.
    Accordingly, where appropriate, the relevant bullet in the 
certification should be edited to reflect that the certification was 
completed within the time frame specified above. For example, the 
bullet in the importer certification that reads: ``This 
certification was completed at or prior to the time of Entry,'' 
could be edited as follows: ``The imports referenced herein entered 
before July 19, 2019. This certification was completed on mm/dd/
yyyy, within 30 days of the Federal Register notice publication of 
the final determinations of circumvention.'' Similarly, the bullet 
in the exporter certification that reads, ``This certification was 
completed at or prior to the time of shipment,'' could be edited as 
follows: ``The shipments/products referenced herein shipped before 
July 19, 2019. This certification was completed on mm/dd/yyyy, 
within 30 days of the Federal Register notice publication of the 
final determinations of circumvention.'' For such entries/shipments, 
importers and exporters each have the option to complete a blanket 
certification covering multiple entries/shipments, individual 
certifications for each entry/shipment, or a combination thereof.
    For shipments and/or entries on or after the date of publication 
of this notice in the Federal Register, for which certifications are 
required, importers should complete the required certification at or 
prior to the date of Entry and exporters should complete the 
required certification and provide it to the importer at or prior to 
the date of shipment.
    For shipments and/or entries made on or after 10 days after the 
date of publication of these final determinations, parties should 
use the exporter and importer certifications contained below that 
incorporate additional information that was not in the preliminary 
determinations certifications. Specifically, the exporter 
certification now requires identification of the producer of the 
merchandise being exported to the United States, and also notes that 
CVD deposits may be required in addition to AD deposits as a result 
of the failure to maintain the required certification or the 
inability to substantiate the claims made in the certification. 
Similarly, the importer certification also notes that CVD deposits 
may be required in addition to AD deposits as a result of the 
failure to maintain the required certification or the inability to 
substantiate the claims made in the certification. The importer and 
Vietnamese exporter are also required to maintain sufficient 
documentation supporting their certifications. The importer will not 
be required to submit the certifications or supporting documentation 
to U.S. Customs and Border Protection (CBP) as part of the entry 
process at this time. However, the importer and the exporter will be 
required to present the certifications and supporting documentation, 
to Commerce and/or CBP, as applicable, upon request by the 
respective agency. Additionally, the claims made in the 
certifications and any supporting documentation are subject to 
verification by Commerce and/or CBP. The importer and exporter are 
required to maintain the certifications and supporting documentation 
for the later of (1) a period of five years from the date of entry 
or (2) a period of three years after the conclusion of any 
litigation in United States courts regarding such entries.
    In the situation where no certification is maintained for an 
entry, and AD/CVD orders from two countries (China or Korea) 
potentially apply to that entry, Commerce intends to instruct CBP to 
suspend the entry and collect cash deposits at the CRS China 
Circumvention Final rates (i.e., the AD rate established for the 
China-wide entity (199.76 percent) and the CVD rate established for 
China all-others rate (256.44 percent)).\9\ In the situation where a 
certification is maintained for the AD/CVD orders on CRS from China 
(stating that the merchandise was not produced from HRS from China), 
but no other certification is provided, then Commerce intends to 
instruct CBP to suspend the entry and collect cash deposits at the 
AD and CVD all-others rates (i.e., 20.33 percent and 3.89 percent, 
respectively) applicable to the AD/CVD orders on CRS from Korea.\10\
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    \9\ See CRS China Circumvention Final.
    \10\ See CRS Orders.
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Appendix III

Importer Certification

    I hereby certify that:
     My name is {INSERT COMPANY OFFICIAL'S NAME HERE{time}  
and I am an official of {INSERT NAME OF IMPORTING COMPANY{time} ;
     I have direct personal knowledge of the facts regarding 
the importation into the Customs territory of the United States of 
the cold-rolled steel flat products produced in Vietnam that entered 
under entry number(s) {INSERT ENTRY NUMBER(S){time}  and are covered 
by this certification. ``Direct personal knowledge'' refers to facts 
the certifying party is expected to have in its own records. For 
example, the importer should have ``direct personal knowledge'' of 
the importation of the product (e.g., the name of the exporter) in 
its records;
     I have personal knowledge of the facts regarding the 
production of the imported products covered by this certification. 
``Personal knowledge'' includes facts obtained from another party, 
(e.g., correspondence received by the importer (or exporter) from 
the producer regarding the source of the input used to produce the 
imported products);
     These cold-rolled steel flat products produced in 
Vietnam do not contain hot-rolled steel substrate produced in Korea:
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain a copy of this certification 
and sufficient documentation supporting this certification (i.e., 
documents maintained in the normal course of business, or documents 
obtained by the certifying party, for example, mill certificates, 
productions records, invoices, etc.) for the later of (1) a period 
of five years from the date of entry or (2) a period of three years 
after the conclusion of

[[Page 70937]]

any litigation in the United States courts regarding such entries;
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to provide this certification and 
supporting records, upon request, to U.S. Customs and Border 
Protection (CBP) and/or the Department of Commerce (Commerce);
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain a copy of the exporter's 
certification for the later of (1) a period of five years from the 
date of entry or (2) a period of three years after the conclusion of 
any litigation in United States courts regarding such entries;
     I understand that {INSERT NAME OF IMPORTING 
COMPANY{time}  is required to maintain and provide a copy of the 
exporter's certification and supporting records, upon request, to 
CBP and/or Commerce;
     I understand that the claims made herein, and the 
substantiating documentation, are subject to verification by CBP 
and/or Commerce;
     I understand that failure to maintain the required 
certification and/or failure to substantiate the claims made herein 
will result in:
    [cir] Suspension of liquidation of all unliquidated entries (and 
entries for which liquidation has not become final) for which these 
requirements were not met and
    [cir] the requirement that the importer post applicable 
antidumping/countervailing duty (AD and/or CVD) cash deposits equal 
to the rates as determined by Commerce;
     I understand that agents of the importer, such as 
brokers, are not permitted to make this certification;
     This certification was completed at or prior to the 
time of Entry; and
     I am aware that U.S. law (including, but not limited 
to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who 
knowingly and willfully make materially false statements to the U.S. 
government.

Signature
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Name of Company Official
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Title
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Date

Appendix IV

Exporter Certification

    I hereby certify that:
     My name is {INSERT COMPANY OFFICIAL'S NAME HERE{time}  
and I am an official of {INSERT NAME OF EXPORTING COMPANY{time} ;
     I have direct personal knowledge of the facts regarding 
the production and exportation of the cold-rolled steel flat 
products that were sold to the United States under invoice number(s) 
INSERT INVOICE NUMBER(S). ``Direct personal knowledge'' refers to 
facts the certifying party is expected to have in its own books and 
records. For example, an exporter should have ``direct personal 
knowledge'' of the producer's identity and location.
     The {MERCHANDISE{time}  covered by this certification 
was produced by {NAME OF PRODUCING COMPANY{time} , located at 
{ADDRESS OF PRODUCING COMPANY{time} ; for each additional company, 
repeat: {NAME OF PRODUCING COMPANY{time} , located at {ADDRESS OF 
PRODUCING COMPANY{time} .
     These cold-rolled steel flat products produced in 
Vietnam do not contain hot-rolled steel substrate produced in Korea:
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  is required to maintain a copy of this certification 
and sufficient documentation supporting this certification (i.e., 
documents maintained in the normal course of business, or documents 
obtained by the certifying party, for example, mill certificates, 
productions records, invoices, etc.) for the later of (1) a period 
of five years from the date of entry or (2) a period of three years 
after the conclusion of any litigation in the United States courts 
regarding such entries;
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  must provide this Exporter Certification to the U.S. 
importer by the time of shipment;
     I understand that {INSERT NAME OF EXPORTING 
COMPANY{time}  is required to provide a copy of this certification 
and supporting records, upon request, to U.S. Customs and Border 
Protection (CBP) and/or the Department of Commerce (Commerce);
     I understand that the claims made herein, and the 
substantiating documentation are subject to verification by CBP and/
or Commerce;
     I understand that failure to maintain the required 
certification and/or failure to substantiate the claims made herein 
will result in:
    [cir] Suspension of all unliquidated entries (and entries for 
which liquidation has not become final) for which these requirements 
were not met and
    [cir] the requirement that the importer post applicable 
antidumping/countervailing duty (AD and/or CVD) cash deposits equal 
to the rates as determined by Commerce;
     This certification was completed at or prior to the 
time of shipment; and
     I am aware that U.S. law (including, but not limited 
to, 18 U.S.C. 1001) imposes criminal sanctions on individuals who 
knowingly and willfully make materially false statements to the U.S. 
government.

Signature
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Name of Company Official
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Title
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Date

[FR Doc. 2019-27816 Filed 12-23-19; 8:45 am]
 BILLING CODE 3510-DS-P