DUTYDRAWBACK - Key Persons

Job Titles:

• Vice President
• Vice President of Comstock

Chris Rittinger is a Vice President of Comstock and Holt and has been with the company since 1997. He has managed some of the largest drawback programs in the chemical industry and has enabled many other diverse companies to maximize their drawback programs. He regularly conducts on-site training for clients. Chris holds a Bachelor of Science in Education and has been a Licensed Customs Broker since 2004.

Job Titles:

• Executive Vice President
• Executive Vice President of Comstock

David Corn is Executive Vice President of Comstock and Holt, starting his drawback career in 2011. David serves as co-lead for the trade in the Trade Support Network's Drawback Working Group, leading efforts to build and transform the duty drawback program through changes to policy, business rules, regulations and statute where possible. David also serves as the co-chair for AAEI's Drawback and Duty Deferral Committee, as the vice chair for the NCBFAA's Drawback Subcommittee, and he represents the New York/New Jersey region as a member of the board to the NCBFAA. In January 2022, David was appointed to the 16 th term of the Commercial Customs Operations Advisory Committee (COAC). In January 2024 he was reappointed to serve on the 17 th term of COAC where he was selected by CBP and his peers to be the COAC Trade lead. David actively discusses drawback with congressional representatives from NJ and NY, and the U.S. Trade Representative's office. David is a frequent speaker on duty drawback in venues across the country each year. David has a Bachelor of Science degree from The Ohio State University in Consumer Affairs and is both a Licensed Customs Broker and Certified Customs Specialist.

Job Titles:

• Chief Executive Officer
• Chief Executive Officer of Comstock & Theakston, Inc

David N. Simcox is Chief Executive Officer of Comstock & Theakston, Inc. and C.J. Holt & Co., Inc. He has served in this capacity since joining the firm in 1975 and is the third generation of family management. He obtained his Customs Broker License in 1977 and moved the business from New York City to New Jersey in 1985. David orchestrated the purchase of competitor drawback specialist, C. J. Holt & Co., Inc. in 1987 as a wholly-owned subsidiary of Comstock. David was instrumental in getting the drawback portion of the Customs Modernization Act introduced into Congress. He has served on the Drawback Committees of NCITD and NCBFAA and represented the broker's association on the Drawback Regulations Team that wrote the current drawback regulations. He has also testified before the House Ways and Means Committee about the importance of duty drawback as one of this nation's only remaining export incentive programs. David has assembled a team of qualified, experienced associates to offer the highest level of drawback knowledge and service possible. Having been an educator himself, he has provided training and instruction for his staff, many of which are now licensed brokers. He has also incorporated education as one of the firm's service offerings, as evidenced by the fact that Comstock is one of the few drawback specialists that provides courses in drawback and import compliance to clients and the general public at their facilities and through various organizations. David has been active in lobbying to influence and change the nature of drawback and is highly involved in the ongoing efforts to streamline and modernize this long-established trade policy.

Job Titles:

• President

Job Titles:

• Vice President
• Vice President of Comstock

Michael Kerlen is a Vice President of Comstock and Holt. He joined the firm in 1988 and became a Licensed Customs Broker in 1991. Michael has developed and managed complex drawback programs for clients in various industries including transportation, apparel and footwear, jewelry, alcoholic beverages, chemicals and petroleum. He has taught drawback and compliance courses for our client seminar series each year and for outside organizations such as the World Academy. He has made presentations at various trade associations and individual companies. Michael has published a number of articles on duty drawback and has been the company's representative at AAEI, American Petroleum Institute, and other organizations' conferences devoted to improving trade programs and expanding duty drawback. His engineering and business background serves him well in this interesting and unique business.

Job Titles:

• Administrative Vice President and Treasurer of Comstock & Theakston, Inc

Steven J. Conti is the Administrative Vice President and Treasurer of Comstock & Theakston, Inc. and Treasurer of C.J. Holt & Co., Inc. He has served in this capacity since joining the firm in 1979. Previously, Steven was employed by Fox and Company Certified Public Accountants. Steven is also the Chief Programmer and Systems Developer for both companies. He has designed and developed the proprietary Drawback Software used today. These Drawback systems have been reviewed, modified, and revised over the years to provide the most up to date and efficient methods to prepare and submit drawback claims. Steven has worked closely with members of U.S. Customs in the design and implementation of various systems used by the Trade and Customs to facilitate the drawback process. Steven manages many of the more complex and involved drawback accounts and is well acquainted with the intricacies of large and detailed operations.