On 24 July 2018, USDA Secretary Perdue announced a $12 billion trade mitigation package that would be administered in three parts: Food Purchases and Distribution, Ag Trade Promotion (to supplement the Market Access Program), and the Market Facilitation Program (MFP). The latter, which will account for the bulk of the funds, would make direct payments to producers of soybeans, sorghum, corn, wheat, and cotton as well as dairy and hogs. Since the MFP payments were to be based on 2018 actual production, there were questions regarding how they would be reported to the WTO in terms of U.S. compliance with its Amber Box cap of $19 billion. At the time, USDA didn’t anticipate that this relief package would cause the U.S. to exceed that all...