What happens when you click Attest.

What gets frozen at attestation

For every entry in your batch, the following is frozen permanently the moment you attest:

None of these values can be changed after attestation. Not by you, not by RefundDesk, not by anyone.

What the audit trail contains

In addition to the calculation snapshot, RefundDesk records at the moment of attestation:

• Your email address — the licensed broker who attested
• Your IP address — the network location at time of attestation
• Timestamp — exact date and time in UTC
• User agent — the browser and device used
• The verbatim statement text — exactly what you agreed to
• A full version history — every subsequent modification to the attestation record, including who made it and when, maintained at the database trigger level via Logidze

These records are retained for 5 years per 19 CFR §111.23 and can be provided to CBP on request.

Why the interest rate is correct

RefundDesk calculates statutory interest under 19 U.S.C. § 1505(c) using the IRS underpayment rate set quarterly under 26 U.S.C. §§ 6621–6622. The rate is applied on a simple interest basis: principal × annual_rate × (days / 365).

The rate applied to each entry is frozen in the snapshot at attestation. If the IRS revises a rate after you attest, your record shows what rate was in effect when you signed.

Why entry date is used as the interest start date

CAPE Declaration CSVs submitted through ACE contain entry numbers but not entry deposit dates. CBP's ACE system does not expose the original deposit date in broker-accessible exports (per CSMS #68340863). RefundDesk uses entry_date as the closest available approximation — the standard practice for CAPE interest calculations. The from_date in your snapshot reflects this and is permanently documented so that if CBP requests clarification, the answer is already in the record.

What divergence means

After you attest, RefundDesk monitors whether the live classification of your entries still matches what was frozen in your snapshot. If a CAPE eligibility rule changes — for example, an HTS prefix is added or removed from the active IEEPA list — the audit dashboard flags entries where the current classification differs from what you attested to.

This does not invalidate your filing. Your attestation captured the rules as they existed when you signed. The divergence flag documents that the regulatory landscape has shifted since your filing.

After attestation: your generated documents

Once you attest, RefundDesk generates and makes available for download:

• CAPE Declaration CSV — formatted to CBP's portal specification, ready for upload to ACE
• Filing Record PDF — the complete protest packet
• Client Summary PDF — plain-language summary for the importer of record
• Entry Schedule CSV — line-item detail for every entry in the batch

You upload the CAPE Declaration CSV directly to ACE through the CAPE tab. RefundDesk does not transmit any documents to CBP.

What to do if CBP asks

The admin audit dashboard at /admin/filing_batches surfaces, for any batch:

1. The exact calculation frozen at attestation
2. The formula in plain arithmetic for each entry
3. The IRS Revenue Ruling that set each rate
4. The statute (19 U.S.C. § 1505(c))
5. The IEEPA HTS prefixes active at attestation
6. Who attested, when, and from where
7. The full version history of the attestation record

The statement you're signing

This statement is recorded verbatim alongside your IP address and timestamp. It does not change between filings.