>> Good afternoon. I'm Latoria Martin with CBP's office of webinar on the modernization of Broker Regulations
111. Before we begin we'd like to let everyone know that this presentation is being recorded.
All attendees are muted and may not share audio or video during the webinar. However, you may
submit your questions in the chat box. If you remember closed captioning during the live event or
when viewing at a later date and time, you may enable the feature by selecting the CC icon in the
lower right-hand corner of your screen. Now I would like to pass it over to Ms. Sharolyn McCann.
>> Sharolyn McCann: Thanks, Latoria, and good morning and good afternoon, everybody. I see that
our participant list is creeping up there to about 930, and we're really excited to be chatting
with you today, so thank you for your time.
As Lato ria said, I'm Sharolyn McCann, director of CP's, trade revenue and -- (audio low) today we
are hosting a webinar focused on the broker modernization regulations. So as I presume everybody
here knows, our broker regulations are found in title 19 of the code Of Federal Regulations
section 111 which we refer to as 19 CFR 111. We published a notice of proposed rule making which
we will refer to as the NPRM, notice Of Proposed Rule Making, on the proposed updates to these
broker regulations two years ago in June of 2020.
We have adjudicated all the comments that were received in response to the NPRM and we've taken
into consideration the concerns and the questions that have been raised in those comments.
As we'll review in a slide shortly, CBP has drafted the final rule, which, when published, will
finalize the updates to the broker regulations. The final rule is currently under review with the
Department of the Treasury and the Department of Homeland Security.
So our objective in conducting today's webinar is to refamiliarize our trade stakeholders with the
proposed regulatory changes included in the NPRM, in the NPRM, I'm going to say that more slowly,
in advance of the final rule publication.
We will published guidance. We will conduct additional webinars when the final rule is published.
So as such, for today's webinar we are not able to provide information on the final rule itself,
nor are we able to speculate when it may be published. And as such, I ask the participants to
refrain from submitting questions in the chat on those topics.
That said, we are confident that the information we are presenting today is tremendously valuable
and will serve to refresh our trade partners on the changes proposed to the broker regulations
with more information to come at the time of publication of the final rule.
So, what we're going to cover today, we're going to cover the broker regulation timeline and not
the estimated publication date, but really where we are in the process of getting to those
finalized broker regs. We will cover a summary of the proposed changes, that is the refresh that
we're talking about. We'll cover broker guidance and resources. And we will also cover our plan
for transitioning those brokers who only have a district permit or district permits to a national
permit. And we'll cover Q&A with any time remaining, and I presume we'll have plenty of time
remaining for your questions that you're entering in the chat pod.
So if we can jump to the next slide, I would love to introduce to you all the members of the team
who are working on this. The broker management branch is letted by Melba Hubbard, who is our
branch chief other members include Jeanine Delgado and Chris Ha who are both international trade
specialists and will be speaking on today's webinar. We also have as members of the broker
management branch Hanna around, Heather Cheshire, Marsha Clark, Kimberly Mac and (). We have in
this slide the broker management contact info, brokermanagement@CBP.dhs.gov. I also wanted to
take this opportunity to introduce a key member of our 111 team and that is Ms. Claudia Bernhardt
who is an attorney with our Office of Trade, Regulations and Rulings. Claudia is a critical
member of our team with vast knowledge on the NPRM and Claudia is also participating in today's
webinar.
So with that, Latoria, we can advance to the next slide and just give a visual on a statement that
I made earlier on where we are in the rule making process. So we talked about the NPRM being
published two years ago in June of 2020. Comments were submitted. CBP has adjudicated those
comments. We have drafted the final rule, and that final rule is currently with DHS and the
Department of the Treasury. Next steps will be final rule publication in the Federal Register and
we will have a delayed final rule effective date. So those are the next steps that we are laying
out.
So with that quick introduction, I would like to turn the webinar over to Jeanine Delgado of our
broker management branch. Jeanine.
>> Jeanine Delgado: Yes. I forgot to unmute. Thank you, Sherry. As Sherry mentioned my name is
Jeanine Delgado, I am an international trade specialist with the broker management branch and
today I'm going to review some of the key changes proposed in the NPRM.
Oh, I'm sorry. Tori, can you advance the slide, please. So there are more proposed changes in the
NPRM than what we are going to review in this hour. Our focus is on some of those key changes we
think you will -- you are most interested in that we've proposed.
I do recommend that you all take time to review the NPRM language to refamiliarize yourself with
what CBP is proposing in the published NPRM.
So in the next few slides I'm going to cover these NPRM components, establishing one national
permit for each broker; the broker fee changes and electronic payment; the broker reporting and
electronic data interface; customs business in the U.S. territory and knowledgeable point of
contact; the broker/client relationship; responsible supervision and control requirements; and
cyber security and records requirements.
Tori, can you advance, please. So, under the one national permission for each broker, the NPRM
proposes to eliminate the district permit and transition to a single permit framework, that's the
national permit, that will operate at the national level within the customs territory of the
United States. It's also proposing to eliminate the need for brokers to request permit wavers and
maintain district offices. Obviously, because without a district permit, there's no need to
request a waiver and no need to maintain an office in a district.
Under the -- and I'll cover the plan that we have put together for this transition in a later
slide.
The broker fee changes and electronic payment, the NPRM proposes to increase the license
application fee for individual and organizations to better align with CBP's processing expenses.
CBP conducted a fee study which demonstrated that CBP's costs are significantly greater than the
current license application fees we're collecting. Those are the $200 fees per application. So
CBP is proposing to increase the fees to $300 for an individual license and $500 for an
organization license application, to recover some of those costs. CBP also proposes to expand
payment options to include electronic fee payment. This would expand on our current use of the
ECPP portal to collect additional broker fee types beyond what we're currently collecting through
the portal, which is the exam application fee and the trinial status fee.
Under broker reporting and electronic data interface, the NPRM is proposing the use of CBP-approved
EDI systems for a number of broker reporting activities. CBP is proposing allowing the broker to
report through a portal, ACE portal account, point of contact information for the broker,
designated recordkeeping contact information for the broker, the broker's change of address
information and the proposal would also codify the current accepted practice of reporting your new
and terminated employees through the portal.
Next slide, please. Under the customs business in the U.S. territory and the knowledgeable point
of contact, CBP is proposing that customs business be conducted within the customs territory of
the United States. That would codify the current practice that we have in place requiring customs
business to be within the U.S. customs territory.
And in the second bullet, the NPRM propose to require that brokers designate a knowledgeable point
of contact to be available to CBP during and outside of normal business hours to be able to
respond to customs business issues. This proposal also includes maintaining a current POC
information with CBP.
Under The Broker/client Relationship, CBP is proposing requiring brokers to obtain a customs power
of attorney directly from the importer or record or drawback claimant and not via a freight
forwarder. This proposal is intended to ensure that the brokers have a direct relationship with
that importer of record and to clarify that the freight forwarder cannot be a barrier to the
broker/client communications.
CBP also proposes to require brokers to report when the broker terminates -- I'm sorry -- when
brokers terminate representation of their client as a result of determining that the client is
attempting to defraud the U.S. Government or otherwise commit to any criminal act against the U.S.
Government.
And then the last bullet, the NPRM proposes CBP to require brokers to advise the client on the
proper corrective action required in cases where noncompliance, error, or omission is identified
by the broker and require the broker to retain a record of that communication with the client.
Next slide, please. Okay. So under Responsible Supervision and Control, CBP is proposing
requiring brokers to submit a supervision plan with a national permit application that would
detail how the entity intends to exercise responsible supervision and control over its customs
business. CBP is also proposing to update and add factors related to responsible supervision and
control to reflect the transition to a national permit framework. We currently have ten factors
and the number would increase in the proposal. And CBP proposes requiring brokers to employ a
sufficient number of licensed brokers to ensure responsible supervision and control over their
customs business.
Under Cyber Security and Records Requirements, CBP is proposing requiring brokers to maintain their
broker records, including electronic records, within the U.S. customs territory. Records
maintenance within the U.S. has already been addressed in a 2020 ruling, and the NPRM proposes to
codify our practice and expectations.
In this last bullet, CBP would require brokers to notify CBP when there has been a breach of
electronic or physical broker records and provide the compromised importer of record numbers.
So that, those are the main points we wanted to bring to your attention that are in the NPRM. Once
the final rule is published, we will provide more information on the changes.
What I'd like to do next is move on to Chris Ha, my colleague, who is going to talk about some of
the resources CBP is developing to support our communications to the trade when that final rule
does publish.
>> Chris Ha: My name is cla, international trade Ha pecialisted from Chris I'm going to go over
few next slides with you. Resources for brokers, we have developed a dedicated web page for
information on the modernization of customs broker regulations, 19 CFR 111, if you go to CBP.gov
and modernization of customs broker regulations that's going to take you to the 111 dedicated
page. On the dedicated web page we have uploaded information such as overview of modernization of
broker regulations, some of the highlights of the purpose change that CBP recommended, and
overview of national permit transmission processes. We include links to NPRM for modernization of
the customs broker regulations and eliminates of custom brokers fee which were published in 2020.
We've been working with developing education -- topical issues, side by side regulation comparison
chart which highlight differences between the current regulations and -- FAQs and other
information to support regulatory changes. All these documents and information will be found at
that 111 dedicated web page once the final rule is published. We will also share with you webinar
information and slide views through the webinars through that dedicated web page. We are going to
leave the link to the web page in the chat for you and we strongly recommend visiting the web page
when you get a chance.
Next slide, please. So broker guidance we are working on developing customs broker guidance, the
document's official name is customs of broker guidance for the trade community. The guidance is
aligned with the current CBP policies and practices at both Headquarters and the field offices it
reflects the regulations changes incorporated in 19 CFR 111 Final Rule. The guidance covers
various topics from customs of broker tests to broker license and process, national permit,
triannual report process and so on. The guidance contains some sample forms and documents that
CBP used in communication with the trade. The guidance also contains some CBP Headquarters
rulings on various broker-related topics and issues. Once the final rule is published we will
upload this guidance document at the 111 dedicated web page at CBP.gov. You did not miss the
publication of guidance document because we will send out a CSMS message to notify you of the
publication of final rule and guidance documents. And the CSMS message will include the link to
the place where the guidance document will be saved and found. So please stay tuned.
I'll turn it over to Jeanine.
>> Jeanine Delgado: Tori, could you go to the next slide, please. Okay. So I'm going to give you
some rundown on the national permit transition process. So in the NPRM, CBP has proposed that we
would provide guidance to those brokers with only a district permit explaining the process to
transition their district permit to a national permit.
So we've -- the broker management branch has been working on developing that process and I want to
give you some information about how we expect that process to work.
So currently, we have about 400 brokers that are operating throughout the nation with only a
district permit. They do not have a national permit. Our plan is to transition this pool of
brokers to a national permit sometime between the publication date and the effective date of the
final rule, so that this pool of brokers will have a national permit which mirrors their current
district permit set up and ready to go.
The current district permits for those, that pool of brokers, will remain active until the final
rule effective date. And, of course, the ACE national permit programming is in place. To set up
the national permit, CBP will be using the broker's current district permit information. So that
national permit will mirror the district permit and it will be sitting pending, waiting until it
needs to come into use.
Each broker that's transitioned to a national permit will be notified that their pending national
permit has been created and they'll be given an opportunity to provide CBP with any address or
permit qualifier information updates that's needed for that document or that permit. CBP will be
sending out more information on this process once we are ready to begin creating the transition.
And that's the extent of that piece I have for you. I think we are now available for questions.
Tori, if you want to move on to the last slide. And I'll hand it over to Melba.
>> Melba Hubbard: Good afternoon, everybody. This the Melba Hubbard with the broker management
branch, and we do have some questions in the chat. Keep in mind, if you do want to ask a
question, please provide it in the chat.
Our first question, will there be more -- a more clear determination of what customs business is?
>> Claudia, do you want to take it.
>> Claudia Bernhardt: I can start, and if you want to add, that works as well. So I guess the
short answer is I think no. There's already a clear definition in the stattout as you all know,
1641 and 19 CFR, we have a regulatory definition in 111.1, 19 USC for the stat oo tuit and there
has been a ruling with a very in-depth analysis of what customs business covers in a 2017 ruling
and I can put the ruling number in the chat if necessary. And then otherwise, it really is a
case-by-case assessment depending on the scenario, and as you all know brokers can always request
a ruling if there is a specific situation that is not covered by those definitions and the
requester needs an answer on Jeanine, if you want to add in I go.
>> No. That was perfect.
>> Our second question, will we receive a copy of the slides after the webinar is over today?
That's the second question. And I would like to say the information that we're providing from
today's webinar is listed on our CBP.gov broker page and we would invite you to look at this
information on CBP.gov.
All right. Third question, good question, do any of the planned changes affect self-filing
importers? I'm not sure if Chris or Jeanine want to take that question. But again, the question
is do any of the planned changes affect self-filing importers?
>> That is a good question and I'm going to say that they don't directly affect a self-filing
importer because these are section 111 pertains to brokers, but they might have an effect on
self-filing for importers only in that, for instance, brokers who have a breach of their records
would need to report that to CBP, which would impact a -- well, actually it wouldn't if you're a
self-filing importer, so I just misspoke there.
So it's -- at this moment I can't call out anything specifically that will affect a self-filing
importer in this regulatory change.
>> Melba Hubbard: All right. Thank you, Jeanine.
>> Jeanine Delgado: So that was a long no.
>> Melba Hubbard: Thank you. All right. Next question. We have some good questions here. Will
CBP maintain a national database of broker license numbers for research by importers to determine
current license status?
>> Jeanine Delgado: CBP does publish the brokers that are actively transacting customs business,
meaning brokers with permits are published both locally at the port level. They are available and
they are available on our website for viewing. We do not publish all licenses that have been
issued to everyone nationally. But if they're transacting customs business, that is publicly
available.
>> Melba Hubbard: All right. Thank you, Jeanine. The next question, for compliance purposes
should we confirm our electronic records are stored in servers that are in the U.S. territory?
>> Jeanine Delgado: I believe you should be reading the ruling that I mentioned, and I'm going to
find the number here. The ruling number is Headquarters ruling 2868. I believe that discusses
electronic records held by third-party providers for the broker. And those should be within the
United States.
>> Melba Hubbard: All right. Our next question, how much time is there between publication date
and effective date of the final rule?
>> Jeanine Delgado: We expect that the time frame will be somewhere between 30 and 60 days.
>> Melba Hubbard: All right. Thank you. Okay. I'm looking to see. Okay. Here's the next
question. For those already on a national permit, will we just remain and how do we submit our
responsible supervision plan?
>> Jeanine Delgado: I'm sorry, Melba, can you repeat that question for me?
>> Melba Hubbard: Absolutely. For those already on a national permit with, I think they mean with
a national permit, will we just remain, and how do we submit our responsible supervision control?
If I can support right here, I think those details will come out with the final rule, but please,
Claudia or Jeanine, jump in and provide any other additional details you might want to add there.
>> Claudia Bernhardt: Just maybe to add, I think the first time you read the question maybe I
misheard, you talked about the supervision plan, and we did propose in the NPRM, if that was the
question, the NPRM that for someone who's applying for a national permit, a supervision plan would
be -- would be an additional document to be submitted. So what we proposed is at the time of
national permit application. So for someone who is -- someone currently has a national permit to
provide that supervision plan, but with the final rule there will be guidance included in the
final rule and on CBP's website on how current national permit holders would have to go about.
>> Melba Hubbard: Okay. Thank you, Claudia. Next question, will the national permit be one time
or annually?
>> Jeanine Delgado: The national permit will operate how our current national permit operates. So
brokers apply for a national permit. We grant the national permit, and annually the broker owes a
user fee; however, that permit remains active as long as you submit your user fee until such time
as you choose to cancel it or, you know, if there were a revocation action that took place.
>> Melba Hubbard: Okay. And I do see a number of questions here a couple of times, I see a really
good question regarding the license broker, you know, ratio to staff. And those details will
certainly will be provided at the final rule. That's not something that we can, you know, provide
numbers today. But we are very happy to hear those questions because it kind of helps us to
focus, you know, our guidance. So I appreciate those, definitely appreciate those questions.
Let me look and see if we have any additional questions. All right. Next question. Will the new
rule detail requirements regarding continuing education, CEUs, I'm assuming that means continuing
education units for the individual brokers.
>> Claudia Bernhardt: So I will take that question. The final rule will cover only proposals from
the NPRM. There was a proposal for continuing education that was published separately by CBP and
CBP will separately adjudicate comments that were received on those and will publish and final
rule that corresponds with that NPRM. So this final rule will only cover the topics that we
propose changes to for new regulations that we proposed from the NPRM from 2020.
>> Melba Hubbard: And I do have someone who asked, Jeanine, if you could reshare the ruling
number. I didn't quite catch it, so I'm sorry, I didn't get that written down. But if you could
reshare that ruling number for I believe the U.S. territory requirement.
>> Jeanine Delgado: Headquarters ruling 292868.
>> Melba Hubbard: All right. Thank you very much. Someone asked here if we could please repeat
the new triennial fee. I don't know if it was the triennial fee, but it was the fee increase.
>> Jeanine Delgado: There is no fee increase for triennial, so there is no triennial fee increase.
That remains 100, that is $100. The proposal, the NPRM proposes to increase the individual
license application fee, processing fee, from 200 to $300, and the corporate or organizational
license application fee from 200 to $500. Those are the only proposed fee amount changes.
>> Melba Hubbard: Okay. Thank you, Jeanine. Let's see here. If there are any additional
questions, okay. Next question. Does the NPRM address the requirement for annual training needs
to maintain a broker's license; if not, what is the latest on this? I can repeat that.
>> Jeanine Delgado: I think Claudia just answered that piece. So the continuing education NPRM.
>> Claudia Bernhardt: Yes. Anything related to training, continuing education, CBP covered in the
NPRM that was published this year, I believe, last year. I'm not as familiar with that one. It
is not covered in this final rule. There will be a separate final rule.
>> Melba Hubbard: All right. A number of people have requested the ruling. We did repeat that
ruling number. That ruling number 292868, Headquarters ruling 292868, just to make sure everybody
got it.
All right. Next question. Can brokers contract people in Mexico to prepare entries?
>> Claudia Bernhardt: Go ahead, Jeanine.
>> Jeanine Delgado: That would be considered customs business and that cannot be done outside of
the U.S.
>> Melba Hubbard: Okay. Thank you.
>> Claudia Bernhardt: I was only going to add, if it's very fact-specific, I think the general
answer Jeanine provided, but if they're fact-specific to a certain scenario, then it depends and
the broker would have to request a ruling if it's something that needs to be decided.
>> Melba Hubbard: Okay. Here's kind of a follow-up question, I think and I think we kind of
answered it. But the question is, when importers handle their own customs business tasks, does
that also need to be done within the customs territory of the U.S.? I would say yes, but I'll let
the panel answer that question. Any further comments on --
>> Jeanine Delgado: I don't know that yes is the answer and I'd recommend that that -- yeah,
that's not a question that we can answer on this webinar. I don't think the importers are --
importers are not subject to the same rules that brokers are in that regard, so I cannot -- I
can't give an answer on that today. Let's find out who that is and we can certainly provide them
an answer after this.
>> Melba Hubbard: Okay. Happy to do that. Okay. Let's see a number of people did ask again for
the ruling number. Okay. That's good, somebody typed it in the chat.
Okay. Next question. Does the new regulations clarify transmitting data to CBP from a foreign
country? I think that's one we're going to have to chew on, maybe some additional details.
Anybody want to --
>> Jeanine Delgado: That's similar to what Claudia and I just spoke to. You know, if you're
transmitting your data from a foreign country to customs, that means probably you're transacting
customs business in a foreign country which is generally not allowed. If you have a specific
scenario that you would like to seek our decision on, please -- please submit it for a ruling.
>> Melba Hubbard: Okay. Thank you, Jeanine. Okay, next question. Will our local permit be
terminated?
>> Jeanine Delgado: So if -- you know, the NPRM proposal to transition to a single national permit
occurs, then once CBP has ensured all brokers have been transitioned, that pool of brokers I
talked about has been transitioned to a national permit and the final rule is in place and the ACE
programming is in place, CBP intends to shut down or turn off or cancel, however you want to call
it, all local permits, correct. They will become defunct.
>> Melba Hubbard: All right. Thank you, Jeanine. Okay. I do want to acknowledge this question,
it may be one we have to take back, but I will provide this question. The next question is, what
will be the guidelines to determine criminal activity and fraud as opposed to possible mistakes?
And that might be one we need to take back, but I did want to acknowledge that question. Any
comments from the panel or should we take that back?
>> Claudia Bernhardt: I think, Melba, you're right, we will take that back. If similar questions
or comments were received with this question to the NPRM, then it has also been addressed in the
final rule. And if additional guidance we believe is necessary, then this will also be provided
once the final rule is published.
>> Melba Hubbard: I think it's Jamie K, how would a broker request to keep electronic records, any
changes on this new rule? I'm not quite sure what you mean by your question. If you could maybe
rephrase your question. Maybe if one of the panelists -- I'm not sure. The question is, how
would a broker request to keep electronic records, any changes on this new rule? I'm not quite
sure what that means, but please type in -- retype your question. We'll be happy to answer it if
we can.
>> Jeanine Delgado: So I will say there are no changes to the section, I think it's -- I should
know this off the top of my head, section I think 163 recordkeeping requirements, there are no
changes to that section. So do I have 163 right? Yes, I do. So if that's what you're referring
to, request for alternate methods of storage, that remains the same.
>> Melba Hubbard: Okay. Thank you, Jeanine. All right. Scanning. I do have another question
here, I'm not really sure what the acronym means. But it says will U.S. VI brokers be out of a
job? USVI is not in customs territory. Is that Virgin Islands?
>> Jeanine Delgado: Yes, that's U.S. Virgin Islands. That, Claudia, maybe you could speak to that
perhaps. These regulations apply to customs brokers within the U.S. customs territory, including
Puerto Rico.
>> Claudia Bernhardt: I am not sure. I'd like to take that question back and provide an answer
later.
>> Melba Hubbard: Okay. Thank you. All right. Let's see. All right. Let's see. A couple of
comments about the ruling number let me see if there's any additional questions here. Here's a
question. Let's see where we are on time. Okay, we're good for time.
Is billing for customs entry considered customs business? So it might depend on who's being
billed, but I'll leave that for the panel.
>> Jeanine Delgado: There is a section about customs -- there is a section in 111 on billing. I
believe -- if you're not going to send the bill -- if the broker is not sending the bill directly
to the importer of record, the importer of record has to have agreed to a waiver for that.
>> Melba Hubbard: All right. Thank you, Jeanine. Here is a good question from Tracy. Will going
to a national permit effectively do away with remote location filing? So basically, how will the
national permit affect RLF filing process?
>> Jeanine Delgado: That is a very good question. So everything now basically is remote location
filing. So some aspects of remote location filing become moot. I don't have anymore information
on that at this point, but we will have some information coming out later when we have a final
rule in place.
>> Melba Hubbard: Okay. Thank you, Jeanine. Next question -- oops, a little blurry here. Let's
see. Has the issue of confidentiality between a broker -- okay. I'm sorry. Let me start over.
Has the issue of confidentiality between a broker and a data processing cloud host been addressed
in the new regulations?
>> Jeanine Delgado: I would suggest -- again, we can't talk about anything in the new regulations,
but I would recommend that you read the NPRM to see what is discussed in there.
>> Claudia Bernhardt: And I would add, if this was a question that was included in one of the
public comments in m response to the publication of the NPRM, then we did address such questions
in the final rule.
>> Melba Hubbard: Okay. Let's see. All right. Somebody was nice enough to post customs business
definition, thank you. There's some of the same questions regarding the ruling.
Okay. Here's a question. I think we're probably going to have to take this question back. The
question is, is ISF and inbound filing considered customs business meaning they must be filed
within the U.S. only regardless if they are assigned to a broker or freight forwarder. That's
kind of a long question and I can repeat that. It might be something that we definitely need to
take back.
>> Jeanine Delgado: Well, I can say that inbound and ISF filing is not considered customs
business. Carriers and freight forwarders can filed inbound and ISF can be filed other than by
the customs broker and the importer.
>> Melba Hubbard: All right. Thank you, Jeanine. Okay, next question. Will brokers still be
managed locally even though there is no longer a district permit? That's the next question. So I
can repeat that. I lost the question.
>> Claudia Bernhardt: A note from me, in the final rule we will discuss on how CBP is going to be
handling all national permit holders and there will be information in time for anyone who needs to
adjust to have that information available.
>> Melba Hubbard: Thank you, Claudia. Thank you. Okay. Next question. Regarding the published
list of brokers, it seems this list is only updated every couple of years. Is there a reason why
this isn't actively updated with new broker information as it changes? I can kind of take this
one. We kind of -- well, I shouldn't say kind of. Our goal is to update our broker list on
CBP.gov quarterly. Occasionally we don't quite hit it on the mark, but certainly we do try to do
quarterly updates for the broker list.
>> Jeanine Delgado: And if they are talking about the filer code list, I'm not sure if that's it,
they are correct in that it's being -- it has been in the most recent years been updated every two
years.
>> Melba Hubbard: Oh, two years. Okay.
>> Jeanine Delgado: That's the filer code list that we publish publicly, which literally just
lists the filer code and the associated entity name.
>> Melba Hubbard: Thank you for that clarification. All right. Let's see. So there are a number
of questions on the POA process, requirements from the broker. I just wanted to mention we do see
those questions in there. Those questions will definitely be addressed in the final rule. Those,
the details will be provided at that time. So today's comments were about the NPRM and we
definitely want to -- I should say we definitely want to acknowledge those questions are here. So
we do appreciate your comments and your input.
So again, it helps us to focus our information. So we will be addressing those issues in the final
rule.
>> Jeanine Delgado: Yes. We'll address them in our information on our public-facing website after
the final rule publishes and before it's effective.
>> Melba Hubbard: And I see we are getting close to time, but I do have one question that I want
to throw out to the panelists. So the next question here is how the brokers will be managed at
the centers. So the question is, can you discuss how brokers will be managed via the center.
Well, it says "C's" but the center.
>> Jeanine Delgado: Yeah. I think that answer Claudia already gave a couple minutes ago that, you
know, the final rule will provide additional information from what the NPRM currently says. We'll
provide additional information in the final rule on that and, of course, also on our public-facing
website.
>> Melba Hubbard: I think we have time for one or two additional questions. Let me see here. I
believe this would be customs business. The question is, would customs business include
responding via e-mail to import specialists and responses to CF-28s and 29s, which are requests
for information and actions taken. So the question is whether those activities qualify as customs
business. Anyone on the panel want to take that question?
>> Claudia Bernhardt: If you can save it, we can take it back.
>> Melba Hubbard: Okay. I think we have time for one, one more question. I do see a few someone
did ask if we could show the slides again. Unfortunately, we are out of time. I don't think we
can get through the slides again. I'm trying to see if they're --
>> Jeanine Delgado: I do want to say, I think, Melba, you already said this, but the information
on the slides that we just presented, most of that information is on our dedicated web page that
is on the modernization of the customs broker regulations that is available now on CBP.gov. So
you can certainly go there to see pretty much all the information that we have on the slides.
>> Melba Hubbard: Okay. We do have just a couple minutes left, so I do want to make sure I turn
it over to our, any of our panelists for closing remarks and our director, Sharolyn McCann, for
any last minute comments, ending comments, rather.
>> Sharolyn McCann: Before I jump in, any of the panelists have additional comments for closing?
>> Claudia Bernhardt: I guess I will say, and I know it's repetitive, but any public comments CBP
received in response to the NPRM have been looked at and reviewed, we've been taking them into
consideration and they will be discussed and addressed in the final rule. Any concerns you
address there will be -- will be addressed in the final rule. And as the other panelists have
mentioned before, we will have sufficient -- or more than sufficient -- you know, lots of guidance
that will be coming out once the final rule is published and there will be enough time for brokers
to read through those new changes that will be coming and adjust, make any adjustments that are
needed to their business. Thank you.
>> Sharolyn McCann: Well said, Claudia. Thank you. And thanks, everybody. I appreciate your
time. Webinar and presentation will be posted on CBP.gov. Much more information to come. We
appreciate the dialogue with everyone as a refresh, again, on the proposed changes in the NPRM for
our broker regulations. And, you know, once we get closer to publication, once we get to
publication, we will have a host of guidance available and follow-up webinars, and so we look
forward to your ongoing participation.
Many thanks for the questions. We will follow up on those that we can answer. And we will work --
I did see a question on this -- we will work to get FAQs posted on CBP.gov for everyone's
visibility for the questions that we are able to answer in advance of the final rule publication.
All right, everyone. Thanks very much for your time. And enjoy your afternoon and your week end.
Thank you.
[Concluded]