Has there been an analysis done as to how the LOC exemptions with interplay with the TPP anti-circumvention requirements? Will the LOC still be able to grant t

Has there been an analysis done as to how the LOC exemptions with interplay with the TPP anti-circumvention requirements? Will the LOC still be able to grant these? If not, the year-long delay may be just long enough that there is actually never an open window.