Warning: 15.2 Million entries are already outside the voluntary reliquidation window.
Stop Waiting for CAPE. Get Your IEEPA Refund Advance in 48 Hours.
SCOTUS has ruled. CBP is building the system. Pilothouse connects you with capital providers who advance up to 75% LTV of your §9903 tariff duties — before the CAPE portal even launches.
SOC 2 Compliant
Data security certified
Financing Intermediary
Not a customs broker
256-bit Encryption
Bank-grade security
Pilothouse A³
Intermediary · Not a lender
180-day protest window for entries liquidated Oct 1, 2025
Entries Impacted
Total Duties at Stake
Importers ACH-Enrolled
To Wire Transfer
IEEPA Asset Recovery Matrix
Based on the Eaton Order (CIT, March 4, 2026) in Atmus Filtration, Inc. v. United States. Where your entries fall determines what facilitated advance Pilothouse can arrange through its capital provider network.
| Entry Status | Days Since Liq. | Required Action | Eligibility | Pilothouse Strategy |
|---|---|---|---|---|
Unliquidated Entry is still "Open" — no liquidation date assigned PREMIUM | N/A (Open) | No protest needed. Wait for CAPE-ordered reliquidation. Pilothouse can advance against expected refund. | Premium Asset CAPE automation covers these | 80–85% Advance Highest quality collateral |
Liquidated Entry has a liquidation date — clock is ticking QUALIFIED | 1–180 Days | Must file Protective Protest (CBP Form 19) immediately via your Broker of Record. Pilothouse assists with preparation. | Qualified Asset Contingent on timely protest | 70–75% LTV Standard bridge loan structure |
Final Liquidated Past 180-day window with no protest filed HIGH RISK | 180+ Days | CIT has NOT yet authorized refunds for these entries. Consult a licensed customs attorney regarding tolling arguments. | High Risk Excluded from CAPE automation | Do Not Advance No current legal pathway |
Entry is still "Open" — no liquidation date assigned
Days Elapsed
N/A (Open)
Pilothouse Strategy
80–85% Advance
Required Action:
No protest needed. Wait for CAPE-ordered reliquidation. Pilothouse can advance against expected refund.
Entry has a liquidation date — clock is ticking
Days Elapsed
1–180 Days
Pilothouse Strategy
70–75% LTV
Required Action:
Must file Protective Protest (CBP Form 19) immediately via your Broker of Record. Pilothouse assists with preparation.
Past 180-day window with no protest filed
Days Elapsed
180+ Days
Pilothouse Strategy
Do Not Advance
Required Action:
CIT has NOT yet authorized refunds for these entries. Consult a licensed customs attorney regarding tolling arguments.
Don't Know Where Your Entries Stand?
Upload your ACE CSV for an instant 180-day wall analysis
How Much Can You Recover?
Enter your estimated IEEPA tariff spend and liquidation date. Our calculator applies the exact 180-Day Wall logic to show your CBP payout, statutory interest, the advance amount available through our capital provider network, and days until forfeiture.
Up to 75% LTV Advance Rate
Our capital provider network advances up to 80 cents on every dollar of your estimated CBP refund, wired within 48 hours of signing the facilitated agreement.
CBP Statutory Interest Included
CBP pays statutory interest on refunded duties per 19 U.S.C. § 1505(c) at a rate set quarterly by the U.S. Treasury. Our calculator uses an illustrative rate for estimation purposes only.
Real-Time 180-Day Analysis
The calculator uses today's date to compute exactly where your entries stand in the Asset Recovery Matrix.
Dynamic CTA Based on Status
Qualified entries are matched with a capital provider for a standard advance. Critical window entries trigger emergency filing coordination. Expired entries route to legal review.
IEEPA Refund Calculator
180-Day Wall analysis · CBP interest included · Pilothouse is an intermediary
Enter your §9903 duty amount above to calculate your advance
The CBP Path vs. The Pilothouse Path
While law firms charge by the hour and CBP builds its portal, Pilothouse delivers liquidity now with full compliance handled for you.
Timeline to Liquidity
CBP Path
4-9 months for actual payout
Pilothouse
Capital provider funds your account in 48 hours
Portal Status
CBP Path
CAPE Portal: Phase 1 launch late April 2026
Pilothouse
Instant Audit: ACE CSV analysis in minutes
Audit Risk
CBP Path
Manual CBP review may trigger additional audits
Pilothouse
We prepare Protest documents; your Broker of Record files them
ACH Enrollment
CBP Path
You must set up ACH independently (required for refund)
Pilothouse
ACH setup coordination included in advance package
HTS 9903 Identification
CBP Path
Manual review of each entry line item
Pilothouse
Pilothouse A³ scans all entries; filters 9903 vs. Section 122
Protest Filing
CBP Path
Requires licensed customs broker or attorney
Pilothouse
Pilothouse prepares; your Broker of Record executes the filing
| Feature | The CBP Path (Wait) | The Pilothouse Path (Now) |
|---|---|---|
| Timeline to Liquidity | 4-9 months for actual payout | Capital provider funds your account in 48 hours |
| Portal Status | CAPE Portal: Phase 1 launch late April 2026 | Instant Audit: ACE CSV analysis in minutes |
| Audit Risk | Manual CBP review may trigger additional audits | We prepare Protest documents; your Broker of Record files them |
| ACH Enrollment | You must set up ACH independently (required for refund) | ACH setup coordination included in advance package |
| HTS 9903 Identification | Manual review of each entry line item | Pilothouse A³ scans all entries; filters 9903 vs. Section 122 |
| Protest Filing | Requires licensed customs broker or attorney | Pilothouse prepares; your Broker of Record executes the filing |
340+
Importers Facilitated
Across 28 industry verticals
$2.1B
Duties Identified
Via Pilothouse A³ Technology
48 hrs
Average Wire Time
Capital provider to importer
Who Is the Importer of Record?
Your shipping terms determine who paid the duties — and therefore who can claim the refund. Confirm your Incoterm before filing.
| Term | Who is the IOR? | Can They Claim a Refund? |
|---|---|---|
| DDP(Delivered Duty Paid) | The Seller | No (Usually) |
| DAP(Delivered at Place) | The Buyer (Your Client) | Yes |
| FOB(Free on Board) | The Buyer (Your Client) | Yes |
Note: Under DDP terms, the foreign seller is typically listed as the Importer of Record and paid the duties — making them the party eligible to claim the refund, not the U.S. buyer. Consult your customs broker to confirm your IOR status before proceeding.
From Upload to Wire Transfer in 48 Hours
The Pilothouse A³ process is designed to be the fastest, most compliant path to IEEPA refund liquidity available today.
Connect
Securely upload your ACE Entry Summary (CSV) or 7501 PDFs. Our encrypted portal reads Entry_Number, HTS_Number, Duty_Paid_Amt, and Liquidation_Date automatically.
Verify
Pilothouse A³ Technology (Audit. Architect. Align.) instantly identifies all 9903-type IEEPA line items, applies the 180-Day Wall matrix, and calculates your total eligible duties.
Fund
Sign the Advance Agreement facilitated by Pilothouse. Our capital provider network funds your wire transfer. Pilothouse coordinates CBP protest filings (Form 19), ACH enrollment, and 7501 vetting throughout the process.
How the CAPE Process Works
CBP is currently in User Acceptance Testing (UAT) for the CAPE module — filings are currently accepted via manual Protective Protests only. Interest is accruing at $650 million per month. Don't let your capital sit idle in the Treasury.
Data Normalization
We pull your ACE Entry Summary data to identify every IEEPA-impacted entry. Our parser filters for HTS Chapter 9903 subheadings and flags entries by status: Unliquidated, Liquidated (within window), or Final.
ACE IntegrationCAPE-Ready Export
We generate the specific CSV format required for the upcoming ACE Claim Portal (CAPE tab). CBP is currently in User Acceptance Testing (UAT) for the CAPE module — the portal is not yet live. Your data will be ready the moment CBP opens the portal for importer filings.
CAPE Portal ReadyProtective Filing Assistance
For liquidated entries within the 180-day window, we assist in preparing the necessary Protests (19 U.S.C. § 1514) to prevent forfeiture. All filings are executed by your Broker of Record or licensed customs attorney — Pilothouse is a financing partner only.
Broker of Record RequiredImmediate Bridge Funding
Pilothouse connects you with capital providers who structure a secured bridge loan against your verified IEEPA refund claim. All CBP refunds are directed to the Importer of Record's ACH-enabled account first — per 31 U.S.C. § 3727.
Bridge Loan StructureCBP has confirmed CAPE is under construction — but interest is accruing at $650M/month.
Don't let your capital sit idle in the Treasury while CBP builds its system. Use Pilothouse to bridge the gap between the SCOTUS ruling and the CAPE payout.
Important Compliance Notices
Pilothouse is committed to full regulatory transparency. Review these notices before proceeding.
Anti-Assignment Act Compliance
Under 31 U.S.C. § 3727, federal refunds cannot be directly assigned to a third party before issuance. Pilothouse IEEPA Advances are structured as secured bridge loans — not refund purchases. All CBP refunds must be directed to the Importer of Record's ACH-enabled bank account first.
Customs Business Limitation
Filing a Protest (CBP Form 19) constitutes "Customs Business" under 19 U.S.C. § 1641. Pilothouse is a financing intermediary — not a Licensed Customs Broker. All protest filings must be executed by your Broker of Record or a licensed customs attorney. Pilothouse assists with document preparation only.
Pass-Through Certification Required
The DOJ is actively arguing that importers who passed tariff costs to customers are not entitled to refunds. To qualify for a Pilothouse advance, you must certify: "My company bore the economic burden of these IEEPA tariffs and did not pass the cost to third parties." Advances against passed-through duties are high-risk and may be unenforceable.
ACH Enrollment Mandatory
CBP mandates ACH enrollment for all IEEPA refunds. As of March 2026, paper checks are no longer issued. If you are not ACH-enrolled in ACE, your refund cannot be disbursed — regardless of your advance status. Pilothouse coordinates ACH setup assistance as part of the facilitated advance service.
Interest Rate Disclaimer
Federal refund interest rates under 19 U.S.C. § 1505(c) are floating — set quarterly by the U.S. Treasury and subject to change. The rate shown in our calculator is illustrative only. The current Q1 2026 Treasury-determined rate may be significantly higher than 3.5%. Actual CBP interest will be determined at the time of refund issuance. Consult CBP or your broker for the current applicable rate.
Section 122 Tariff Distinction
Importers are currently paying new 10% tariffs imposed under Section 122 (effective February 2025). These are separate from and NOT refundable under the IEEPA ruling. Our calculator and CSV parser only advance against HTS Chapter 9903 IEEPA duties. Advancing against Section 122 duties would result in total loss of principal.
Required Eligibility Certifications
Upload Your ACE Entry Summary for Instant Analysis
Our Pilothouse A³ parser reads your ACE CSV export using the exact CBP column headers — Entry_Number, HTS_Number, Duty_Paid_Amt, Liquidation_Date — and applies the 180-Day Wall matrix to every entry in seconds.
What the Auto-Scan Detects:
Data Privacy Guarantee
Your ACE data is processed locally in your browser and never transmitted without your explicit consent. SOC 2 Type II certified.
ACE Entry Summary Auto-Scan
9903 filter · NULL handler · Daily interest formula · Protest Schedule export
Drop your ACE Entry Summary (.CSV) here
or click to browse · .csv format only
Don't Let Your Refund Rights Expire
Every day without a protest filing is a day closer to permanent forfeiture. Pilothouse has helped importers identify over $2.1 billion in IEEPA duties and connect them with capital providers. Start your facilitated advance today.
CAPE & IEEPA News
Curated updates from authoritative legal and trade publications · Updated March 2026
CBP Provides Further Details on IEEPA-Related Refund Mechanism
CBP filed a second progress report confirming the CAPE system's phased rollout. The Refund component is now approximately 60% complete. CBP confirmed ACH enrollment is mandatory — thousands of importers are currently blocked from receiving refunds due to missing ACE enrollment.
CBP CAPE Refund System Update: Four-Phase Rollout Confirmed
CBP's March 19 court filing confirmed the CAPE system will deploy in four phases: (1) Claim Portal in ACE, (2) Mass Processing of unliquidated entries, (3) Review & Reliquidation of liquidated entries, and (4) Refund issuance. Phase 1 portal launch expected late April 2026.
IEEPA Tariff Refunds: Current Status and Next Steps for Importers
JD Supra analysis confirms that importers with liquidated entries must file protective protests under 19 U.S.C. § 1514 within 180 days of liquidation. Entries that are 'final and conclusive' (past the protest window with no protest filed) are currently excluded from the automated CAPE process.
Is Your ACE Enrollment Blocking Your IEEPA Tariff Refund?
Since February 6, 2026, CBP transitioned to an all-electronic refund system. ACE enrollment and ACH setup are now required to receive any electronic payment from CBP — including IEEPA refunds. There is no paper check alternative. Importers must confirm enrollment immediately.
U.S. Customs Files Update: Tariff Refund Process In Progress
On March 6, CBP filed a declaration requesting a 45-day extension for ACE system updates to handle the massive volume of refund processing. CBP confirmed that the March 4 CIT order remains stayed pending completion of the CAPE system build.
U.S. CBP Provides Update on IEEPA Duty Refund Process
CBP is developing new ACE functionality to automate and centralize IEEPA tariff refund claims. The CAPE system will allow importers to upload CSV files of their entries directly through a new 'CAPE' tab in the ACE Portal. CBP estimates the Refund component is 60% complete as of March 11.
News Disclaimer: The above items are curated summaries from publicly available legal and trade publications for informational purposes only. Pilothouse Structured Debt Finance (a DBA of Rhino Consulting LLC) does not author or endorse these third-party publications. This content does not constitute legal, tax, or financial advice. Consult a licensed customs broker or attorney for guidance specific to your entries. Contact Pilothouse at 800.507.3557 or www.pilothouse-sdf.com.