What the coach watches for: tariff-refund recovery calls

This page describes the compliance rule set RingMentor applies to business-to-business calls that qualify US importers for an IEEPA tariff-refund recovery service and walk them through the application. It is written for the people who run those calls and for the clients they run them for. It is not legal advice, and RingMentor does not certify compliance. The coach flags language against the rules below and against your own rules; your organization and your client decide what your reps say.

Rule set current as of September 2026. Rules are reviewed as the law and the CBP refund process change.

Who this applies to

• Reps who qualify importers and walk them through the application on the same call. These reps are not customs brokers, CPAs, or attorneys, and the rules assume that.
• Managers who review calls and tune the coach.
• Your client (the company whose program the reps represent), whose own rules are loaded alongside these.

The coach reads both sides of the call. Every flag a rep sees is a short suggestion with the safe line attached. The rep is always in control; nothing here makes a legal determination.

The rules, in plain English

Each item says what the coach flags and what the rep says instead.

1. Say who you are. We flag it when a rep implies the call is from Customs, the Treasury, a court, or “a government program,” or lets an importer’s “so this is Customs?” go uncorrected. Instead: name the company, say it is a private company, and say plainly that it is not CBP or any government agency. Your client’s own shorthand for the refund is fine; the flag is on the governmental framing, not the name.

2. No promised refund, amount, or percentage. We flag it when a rep tells an importer what they will get back, quotes a figure or a percentage as a result, or says the outcome is certain. The application’s estimate is a range and is presented as one. Instead: “This is a range, not a final number. The accounting team verifies everything.”

3. Program facts stay accurate. We flag it when a rep says a refund is approved, automatic, already set aside, or that CBP must pay once something is submitted, or gives a payout date. Instead: describe the process as your client has approved it, keep CBP’s own qualifiers (“valid refunds are generally issued within 60 to 90 days after acceptance”), and route questions about entries in the litigated category to the team.

4. Who files. Only the importer of record or its licensed customs broker files the refund declaration with CBP. We flag it when a rep says “we file,” “we submit it to Customs,” “you don’t need a broker,” or offers to use the importer’s ACE login. Instead: “A licensed customs broker handles the filing with CBP. We help gather and organize the information.” If your client works through a network of brokers rather than one named broker, say that; the coach does not expect a broker’s name.

5. No customs, tax, or legal advice. We flag it when a rep decides whether the importer is the importer of record, whether entries are eligible, what an agreement means, what the tax treatment is, or gives an individualized deadline. We also flag a rep steering an importer away from their own attorney, CPA, or broker. Instead: read the approved description or route it: “That’s a question for the licensed broker, the accounting team, or your attorney.”

6. No manufactured urgency. We flag it when a rep invents a cutoff, a closing deadline, or a running-out fund to get a same-call signature. Instead: “There’s no cutoff on today’s call. Timing on specific entries is something the team reviews with you after they look at your data.”

7. The importer’s answers are the importer’s. We flag it when a rep supplies, suggests, rounds up, or anchors an answer or a number, including nudging the estimator’s inputs higher. Instead: ask the question again and record what the importer says. “I don’t know” is a valid answer in the application.

8. No fees, no financial details, no identifiers by phone. We flag it when a rep asks for any payment, card, bank account, Social Security number, ACE password, or ID image, or offers to enter the importer’s information for them. Instead: “Have your EIN and a government ID ready. You enter everything in the portal yourself.”

9. Agreements get explained, never rushed. We flag it when a rep tells an importer not to read an agreement, to “just scroll and sign,” describes a document as meaningless, discourages a review by the importer’s own advisors, or offers to sign for them. Instead: walk through each agreement with its approved description, and honor “I want my attorney to look at this.”

10. Advance funding stays with the funding team. We flag it when a rep describes rates, fees, amounts, approval odds, timing, repayment, or the legal character of the funding option beyond the approved script line. The funding option applies to a claim that has already been filed, so we also flag it when a rep offers it before that point. Instead: “Our funding team can walk you through a specific offer.”

11. Recording disclosure comes first. We flag it when qualifying questions start before your approved recording line is delivered, when a rep denies an active recording, or describes live transcription as “just notes.” Instead: deliver your organization’s approved recording line at the top of the call, before the first qualifying question.

12. Location stays truthful. We flag it when a rep claims to be somewhere they are not or leans on “we’re local.” Instead: when asked, say where you are working from and that the company is US-based.

13. Stop means stop. We flag it when a rep keeps pitching, asks “can I ask why,” or offers another channel after an importer asks not to be called. Instead: confirm removal and end the call.

14. The right person signs. We flag it when a rep proceeds to the agreements after the contact says they are not authorized, or suggests someone else sign for the company. Instead: “The agreements need to be signed by an officer or owner who can sign for the company. Who is the right person, and when could we walk them through it?”

15. Credibility claims need backing. We flag it when a rep improvises or inflates claims about headcount, volume, track record, approval rates, or endorsements beyond what the approved script says. Claims your client has substantiated and approved are recorded and not flagged; improvisations around them still are. Instead: “I don’t have that number in front of me; the team can send it to you.”

What the coach does not do

• It does not scrub your lead lists, manage do-not-call records, or set calling hours. Those live in your dialer and your lead-source agreements.
• It does not decide who your customs broker is or manage powers of attorney and refund-routing forms. That is your client’s and the broker’s work.
• It does not approve or disapprove your client’s funding product. Provider-level disclosures under state commercial-financing laws are the provider’s responsibility.
• It does not write your recording disclosure. Your organization or your client’s counsel chooses the wording; RingMentor reminds the rep and captures that it was said.

How flags work on a call

A flag is a short suggestion with the safe line attached. Reps can dismiss it. Managers see the moment afterward with the transcript. If a rule fires on language your client has approved, tell us and we record the decision; the coach stops flagging that exact line and keeps flagging improvisations around it. Rules in the first category (guarantees, false status, fees, coached facts, denying a recording) do not have that option.

RingMentor provides call-coaching software. Nothing on this page is legal advice. The rules reflect research current as of the date shown above and are reviewed as the law changes; validate them with your own counsel.