CAPE Refund Came Short? Why It Happens and What to Check

TL;DR — A CAPE refund can arrive lower than the amount shown in REV-603 or ES-022 for five reasons: CBP applied a Funds Diverted offset under 19 CFR § 24.72, the entry was netted against under-paid lines under 19 CFR § 159.1, only some of the entries you filed have liquidated yet (liquidation-date batching), the refund covers principal but interest is in a separate transmission, or part of the declaration was rejected at entry-specific validation. The Refund Secondary Status column in REV-603 tells you which.

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How CBP issues CAPE refunds (and why the amount can change)

The CAPE process has four steps where an amount can be adjusted before it reaches your bank account.

First, ACE validates the CSV and either accepts each entry or rejects it. A partial-acceptance scenario — some entries valid, some rejected — is the first place expected and actual diverge. Per CSMS #68340863, if any entry fails the entry-specific validations, ACE removes that entry from the declaration but continues processing the rest.

Second, CBP reliquidates accepted entries. Per 19 CFR § 159.1, reliquidation nets all over- and under-payments for the entire entry, not just the IEEPA component.

Third, refunds are consolidated. CSMS #68340863 confirms: "The individual entry summary refunds will be consolidated by IOR or designated 4811 party and liquidation date before they are dispersed in one lump sum."

Fourth, before Treasury transmits the ACH, CBP applies any outstanding debt offset. CSMS #68340863 again: "a check for any unpaid debts to CBP will be made before the issuance of the refund, and the refund amount will equal the difference between the IEEPA duties to be refunded and the unpaid bill(s)."

Each adjustment step is invisible until you see the result in REV-603 or in your bank account.

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Five reasons a CAPE refund lands short

1. Funds Diverted offset (19 CFR § 24.72). CBP applied an outstanding debt against the refund before payment left Treasury. REV-603 shows "Funds Diverted" in the Refund Secondary Status column. No advance notice is given.

2. Entry-level netting (19 CFR § 159.1). During reliquidation, CBP nets over- and under-payments across the whole entry. If the entry had under-paid lines outside IEEPA — for example, an MPF miscalculation or a Section 301 line under-deposited — that shortfall is subtracted from the IEEPA refund.

3. Liquidation-date batching. Only entries that have already liquidated are in this payment. Unliquidated entries in the same CAPE Declaration refund in later batches as each liquidation completes. The full mechanics are covered in why CAPE refunds arrive in batches.

4. Principal arrived, interest still in flight. ES-022 shows refund amount and interest amount as separate columns. Treasury can transfer principal and interest in separate ACH wires. If the deposit matches principal but not principal-plus-interest, interest is coming in a later transmission.

5. Partial declaration acceptance. Some entries in the CSV were rejected at entry-specific validation. CSMS #68340863 lists the rejection categories: entries flagged for Reconciliation, Type 09 Reconciliation entries, entries with an Open or Suspended Protest, AD/CVD entries in pending liquidation, entries over 80 days past liquidation, and entries where goods value was reported on the IEEPA HTS line. Rejected entries don't refund.

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What "Funds Diverted" means in REV-603

CSMS #68536553 (May 4, 2026) introduced the Refund Secondary Status column in REV-603 and defines Funds Diverted as: "This status indicates that funds have been diverted for an existing bill. Diversion occurs after liquidation of the entry summary, before the refund is issued."

The legal basis is 19 CFR § 24.72, which reads in part: "When an importer of record or other party has a judgment or other claim allowed by legal authority against the United States, and he is indebted to the United States, either as principal or surety, for an amount which is legally fixed and undisputed, the port director shall set off so much of the judgment or other claim as will equal the amount of the debt due the Government."

The critical phrase is "legally fixed and undisputed." CBP can only offset against debts that are already established — not against potential or contested claims. In practice this means one of four things:

• An open bond claim against the importer's customs bond
• An unresolved penalty notice from a prior entry
• An earlier reliquidation that increased duty owed and was not paid
• Under-paid AD/CVD duty on a prior entry that was finalized

In every case, the debt is something that appears in the importer's own customs records. If a refund came short with Funds Diverted status, the offset amount equals an existing CBP receivable.

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How to find the offset amount

Open bills against your IOR are listed in your Importer sub-account in ACE. Run a Statements report from the Importer sub-account to see open bills with amounts. The Funds Diverted offset will equal the amount of one or more of these bills.

If the bills total exactly matches your missing amount, that confirms the offset cause. If no open bills appear, the offset may relate to a closed entry that was reliquidated upward — pull the entry summary detail under the relevant entry number to verify.

For a structured walkthrough of how to read each ACE report in sequence, see the REV reports guide.

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When the missing money is not lost — it's coming later

The most common cause of a "short" CAPE refund is not an offset. It's liquidation-date batching.

CBP groups refunds by IOR plus liquidation date. An importer who filed a single CAPE Declaration with 100 entries will not receive one payment for all 100 unless every entry shares the same liquidation date. Each group of entries sharing a liquidation date triggers its own ACH transfer.

If REV-603 lists all 100 entries but only 12 show "Treasury Issued" status while the other 88 show no secondary status at all, the 88 are simply still in the queue. Their refund arrives once their liquidation cycle completes. See why CAPE refunds arrive in batches for the timing breakdown.

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When part of the declaration was rejected at validation

CSMS #68340863 explicitly states that entry-specific validation runs after file-level validation: "If an entry summary fails any of the entry-specific validations listed above, ACE will remove that individual entry summary from the CAPE Declaration but will continue processing the remaining entry summaries listed."

Common rejection reasons that reduce the apparent refund:

• Entry flagged for Reconciliation (Type 09 entry summary)
• Entry summary associated with a Drawback entry, or a Type 47 Drawback entry
• USMCA Type 08 Duty Deferral entry
• Entry summary with an Open or Suspended Protest
• Entry summary with "open" or "closed" liquidation status, like a Temporary Importation under Bond entry
• AD/CVD entry summary in pending liquidation status
• Entry summary over 80 days past the liquidation date
• Goods value amount reported on an IEEPA HTS line instead of on a Chapter 1-97 classification

The CAPE Tab in ACE shows the per-entry rejection reasons after acceptance. If your refund total is missing the value of specific entries, check the Tab first to see which entries were dropped.

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When to email CBP and what to write

For entry-level disputes — refund amount appears wrong on an accepted entry — write to IEEPARefunds@cbp.dhs.gov with the CAPE claim number, the entry number, the expected refund amount, and the amount received.

For rejected ACH payments — REV-613 shows entries with rejection status — write to frn-achrefundsupport@cbp.dhs.gov with the same details plus the ACH enrollment confirmation date.

Funds Diverted itself is not disputable through customer service. The offset is mandatory once a debt is "legally fixed and undisputed" under 19 CFR § 24.72. To recover the offset, the underlying debt must be addressed separately — paid, contested through the proper protest mechanism, or proven satisfied.

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How a Pre-CAPE audit catches some of this before you file

Some refund shortages are unavoidable — Funds Diverted offsets reflect debts that exist independently of CAPE. But others can be caught before filing:

• Entries that will be rejected at entry-specific validation can be identified by their type, status, or liquidation date before they go in the CSV
• Entries near the November 10, 2025 rate change can be flagged for review so the refund expectation matches the rate that will actually apply
• Entries with goods value on an IEEPA HTS line can be flagged for PSC before CAPE submission, since PSC is blocked after CAPE acceptance

The Pre-CAPE Audit runs these checks automatically on an ES-003 export and returns a Green/Yellow/Red verdict per entry.

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Frequently asked questions

Can CBP take my refund for an unrelated debt? Yes. Under 19 CFR § 24.72, CBP must offset against any debt that is "legally fixed and undisputed." The debt does not need to be related to the entry being refunded.

Does CBP notify me before applying Funds Diverted? No. The first notification is the Refund Secondary Status column in REV-603. The offset is applied automatically before Treasury transmits the ACH.

How do I dispute a Funds Diverted offset? The offset itself is mandatory and not separately disputable. To recover the diverted amount, the underlying debt must be addressed — paid, contested through the proper protest mechanism, or proven satisfied. Then CBP releases the held portion.

Will the rest of my refund come later? If the shortage is due to liquidation-date batching, yes — each remaining group of entries triggers its own ACH payment when it liquidates. If the shortage is due to § 24.72 offset or § 159.1 netting, no — that amount is settled against the debt or underpayment and will not return.

My CAPE Declaration was accepted but I haven't received any money. Is that normal? Yes, if the entries are unliquidated. Per CSMS #68340863, unliquidated entries accepted in CAPE are set to liquidate 45 days from the CAPE Declaration acceptance date. Refund follows 60-90 days after acceptance, with that window including the 45 days for CBP review plus additional time to process the refund through Treasury. Total wait for newly-filed unliquidated entries can reach 105-135 days from acceptance.

Some entries on my CAPE Declaration don't appear in REV-615 at all. What happened? Those entries were rejected at entry-specific validation per CSMS #68340863. ACE removed them from the declaration but continued processing the rest. Check the CAPE Tab for the per-entry rejection reasons.