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Again we wish to point out that the forfeiture provisions of section 3 (d) are too harsh. Triple damages, in terms of a cargo of wheat, would mean a penalty of nearly $2,000,000. The remote possibility of such a forfeiture cannot be said to encourage exports. We believe the penalty is more than an "effective sanction” to assure fulfillment of the agreement. We regard it more as a deterrent to free trade in wheat at the international level. We suggest that, if sanctions as severe as this are necessary to accomplish the ends international commodity arrangements are supposed to develop, the Congress should now revalue ends to determine if they warrant the means now proposed to accomplish them.

I would appreciate your incorporating this letter in the report of hearings by your subcommittee. With kindest personal regards, I am, Sincerely yours,

WILLIAM F. BROOKS,

Executive Secretary. Х

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