>> CALENTHIA BANKS: Good afternoon,
ladies and gentlemen my name is Len
Banks with the Office of Trade Relations
thank you for joining us today. Today's
webinar is: Continuing Education: New
Requirements for Individual Licensed
Customs Brokers we have an expected
duration of about one hour. We have a
few housekeeping items.
Everyone will be kept on mute during
the presentation. So that we can keep
the line clear of background noise. If
you have any questions or comments, we
invite you to type them into the chat
box at any time during the
presentation.
We will be holding all questions to
the end of the presentation. And we
will answer as many as we can from the
chat box during the Q&A period.
The continuing education credit code
will be placed in the WebEx chat box
throughout the presentation.
Today's presenter is commercial
operations revenue and interdivision
Director Shari McCann, Ms. McCann, over
to you.
>> SHARI McCANN: Thanks, Len, and
good afternoon, everybody.
As lymph node mentioned my name is
Shari McCann -- as Len mentioned -- I am
the Director for the Commercial
Operations, Revenue and Entry within
the Office of Trade at U.S. border
protection. Our webinar today will
cover the new continuing education
requirements for individualized
licensed custom brokers by the broker
continuing education Final Rule that was
published on June 23rd, just this past
year. This year, June 23rd.
So every day customs brokers
facilitate the movement of an estimated
107,000 shipments worth 9.2 billion into
the United States.
The new continuing education
requirements will help to ensure that
customs brokers stay up to date on U.S.
trade laws and regulations. And
therefore, enhancing compliant trade and
protecting against illicit trade
entering the U.S. commerce in an
increasingly interconnected global trade
environment.
Under the new regulation, each of
CBP's 13,000 individualized licensed
customs brokers will be required to earn
36 hours of continuing education every 3
years on the evolving customs rules and
related U.S. trade laws in order to
maintain their valid license. Beginning
with the upcoming 2024 to 2027 triennial
status period and that compliance
timeline is a primary message that
you're going to hear the team emphasize
today to ensure that all of our
individual licensed customs brokers
understand when they have to start
earning continuing broker continuing
education credits.
Again, individual brokers will be
required to begin earning requirements,
earning continuing education credit, in
the 2024 to 2027 triennial period.
And the team will share further
specifics surrounding this initial
triennial period and continuing
education during today's webinar.
So you'll find more information and
resources on the continuing education
requirements on our continuing education
webpage that the team will share with you
in today's webinar.
We encourage individual customs
brokers to continue monitoring our
continuing education webpage for updated
information on these continuing
education requirements.
I'd like to add that you can submit
any questions related to continuing
education to our dedicated email inbox
which is continuingeducation -- one
word.
Continuingeducation@CBP.division.gov.
And now to get the webinar started I
would like to turn it over to Heather
Cheshire of our team to review today's
webinar agenda and introduce our team.
Over to you, Heather.
>> ELENA RYAN: Hi, thanks, Shari,
before we get started I just want --.
>> HEATHER CHESHIRE: Thanks, Shari
before we get started I want to go over
housekeeping we went over but I'm going
to do it again this has been recorded and
it will be posted on the continuing
education webpage along with the slides
at a later date . Please stay muted and
don't share your audio throughout the
webinar.
Again, put your questions in the
chat and we will address them at the
end, as many as we can.
And if you require closed captioning,
select the CC at the bottom left of
your screen. Next slide.
In this webinar, we will provide a
quick introduction of our team, walk
through the new continuing education
requirements, and we'll discuss next
steps in the short- and long-term for
brokers and aspiring accreditors.
Next slide.
All right. So here is the
continuing Education Team.
We already met Shari, she's our
Division Director. Elena is the special
advisor.
She has been working on continuing
education for a few years.
Omar is our Branch Chief for the
Broker Management Branch. And Marcia
and Tiarah and I work under Omar and
Shari.
And we will be answering any
questions that come into the continuing
education inbox. The email is below.
Shari said the email to you. We
just want to make sure you're emailing
this mailbox and not broker management
about anything regarding continuing
education.
Next slide, please.
Okay.
Let's discuss the overview of the
continuing education Final Rule.
The Final Rule, like Shari said,
amends CBP regulations to require
continuing education for all active
individual customs broker license
holders. And it also creates a
framework for administering this
requirement.
Active individual license holders
which refers to a broker with a license
that has not been suspended will be
required to take 36 hours of continuing
education every three years which works
out to one hour a month.
Individual licensed customs brokers
will report the completion of their
education as part of their triennial
status report.
I just want to note corporate
license holders will not have a
continuing education requirement.
You may be asking this question in
your head, do I need to meet the
continuing education requirement for the
upcoming triennial period in February
2024? No.
You will not have to do this until
the next triennial, which begins in
2024. And goes to 2027.
Additionally, CBP will not require
the full 36 hours in the initial
triennial period. And we will publish
the number of required education hours in
a future Federal Register Notice.
Once the educational opportunities
are available, they will be located on
CBP gov and that will include CBP gov
webinars and events along with relevant
partner Government agency, PGAs, and
their training opportunities.
The next step will be for CBP to
solicit for and select accreditors who
will review and approve non-Government
training content for the continuing
education program.
Next slide, please.
So we're taking several steps, which
we will talk about in this slide and in
the next three slides. In preparation
for full implementation of the CE
program.
We're shooting for -- within 120
days of the Final Rule that we will host
some public webinars like this one to
communicate new requirements and the
implementation progress.
We will issue a Request for
Information. That's an RFI for
potential accreditors, as well as hold
Industry Days sessions for the interested
parties.
And finally, we are targeting an
issue date by early 2024 to release a
Request for Proposal, the RFP, to
solicit continuing education
accreditors.
Now I'll turn it over to Elena to go
over the next few slides.
>> ELENA RYAN: Thank you so much,
Heather, thank you, all for joining us
today and we hope you get a lot of
information and we look forward to
taking your questions at the end of the
presentation.
So where Heather left off is sort of
our initial short-term plan. Where
we're looking to issue both a Request for
Information, that's the RFI, and the
Request for Proposal, which is the RFP.
The reason why we're doing that is
because this is a brand-new program with
brand-new requirements for all of you.
And for us, as well.
And we just wanted to make sure that
we have the absolute best available
information most complete information as
possible to make sure that we were
listening to as many voices as possible
as we proceed.
So the RFI is basically it's exactly
that. We're saying, hey, give us all the
information that you can provide us.
We are going to sit down with folks
for one-on-one presentations.
We're calling those Industry Days.
And they will tell us what they find to
be the most important aspects of
continuing education.
And see if there's anything we've
missed. And we'll have the opportunity
to exchange information.
Anybody who would like to
participate in Industry Days will make
that very clear in the RFI process
document. And we will make a
appointments with folks so people know
when they will be able to present .
We're going to provide a couple of
different options because of COVID and
because of travel and because of
schedules we're going to have the
option of you can either present to us
in-person in sort of the normal
conference room setting. Or if you
would prefer to do a webinar like this
one with us, that will work, too. Or
some hybrid.
And from there, we will gather all of
the information that we have. And we
will put together a Request for
Proposal.
And I believe that's on our next
slide.
Thank you.
So then we are going to put together
this Request for Proposal. People will
respond to a proposal. This is a
non-monetary award.
And we are not looking to select
just one accreditor. So we'll have
multiples.
We don't know how many.
We want more than one. We probably
don't want 101. But we think we're
going to get a good number that will
provide people a lot of variety and
opportunity when they would like to get
their coursework reviewed and hopefully
accredited.
This is really, really important,
folks, CBP is not an accreditor.
So when you come to us and say, hey,
I have this thing going on, can I count
it as continuing education? We aren't
going to be the ones who say yes or no
on that because we aren't the
accreditors. You'll have to go to one of
the approved accreditors. How will you
know who these folks are? Great
question. We're going to publish that in
the Federal Register Notice that will be
published once we have made our
selections. And that's going to tell
you who the accreditors are. How to get
to them. Obviously websites and things
like that that's going to be -- make it
as easy as possible for you to get to the
accreditors, we will update our webpage
to have them listed there. It will be
very obvious to you what your next steps
are. We're also going to tell you the
number of credit hours that you need to
get between now and the 2027 reporting
period. Excuse me.
As we can't say this enough, as
Heather said, as Shari said, you do not
have to get any credit hours between now
and 2024 reporting period.
We are getting things set up. You
do not have to do anything.
Now, I'm going -- in a few slides
I'm going to say, but wait, there's some
stuff you can be doing but it's not
going to be retirement. It's just best
practices.
After we do the selection process, we
are going to work pretty much hand in
hand with the accreditors to build the
program. And when they are ready to go,
you will also know it. When you are
able to start submitting things for
accreditation and where you can find
different programs.
We are also going to be working with
the other partner Government agencies
that we have that have a close tie or
lots of activity with CBP to make sure
that activities that they are doing that
would be relevant to you as customs
brokers also count for credit and of
course those things are very often free
very often online there's just some great
opportunities for you all and we want
to be sure you can tap those as
necessary.
All right. Folks, I believe I
covered just about everything on this
slide so we can move to the next.
Okay. As I said, you don't have to
do anything as a regulatory requirement
in the next couple of months before the
2024 triennial reporting period. But
that doesn't mean there aren't things
that you can do.
I know you all have read the rule
cover to cover. There will be a quiz
here at the end. I kid.
But do read the rule. It's helpful.
I also found it helpful in preparing
for this webinar to read through the
NPRM. And that was the Proposed Rule
that was back a couple of years ago.
We put forth a lot of things in
there. And then of course we responded
to them. But there was a lot of
information that didn't carry directly
over to the Final Rule. In the
preamble. That you might find useful
and you know get the juices flowing
there, as well.
If you work for a company that has a
standard training for its broker or
broker employers or those working in
international trade compliance, continue
to take all of those trainings that your
company requires. Obviously we aren't
interfering in that process. And you
shouldn't be sitting on your hands
waiting for a thumbs up or thumbs down
from all of us or any accreditors to
take training that your company
requires.
So make sure you keep up with that.
If you are currently enrolled or I
don't know if enrolled is the right
word. But if you're a current recipient
of the CCS certificate or the CES
certifications, go ahead and keep doing
those things.
We envision that that will be
approved credits. We made that
assumption in our economic analysis in
both the NPRM and the Final Rule.
Keep on doing those things. We know
those are valuable to you.
And you get a lot of use out of
them. As part of your marketing as a
broker.
So please don't stop those
activities if you are involved in them.
And if you're interested in starting
that's a good thing to start exploring.
Keep on attending events that cover
customs topics of relevance and
importance. Sometimes those are the
national level. We used to call them
Trade Days we call them something
different now but we used to have -- or
we do still have an Annual Conference
that you can attend that is the kind of
thing that will be available for
credit.
There are port days that our port
directors at the local level will put
out where they host you all and have you
come in and talk about important events
those kind of things are good to keep on
attending.
Many of you are good old friends to
the CBP webinars particularly the NCSD
-- that NCSD puts on. Keep on doing
those kinds of things. We are happy to
put those on as a free activity. And we
hope you get use out of those. Keep on
going.
Then start looking around at your
life and seeing what kinds of things
that you're doing on an everyday basis
that might be able to qualify for credit
hours and I've put a few things there.
Attending program meetings of either
your local Association for the Study of
African American Life and History or
your regional association or the
national.
Again, we mentioned the NCSD webinars
that CBP hosts on a fairly frequent
basis. Again, the Trade Days and
whatever online training courses you find
useful whether that's formal such as
the CCS certification, other
certification, or things that you just
find useful.
And make sure that you are doing all
of your other requirements that are
contained in 19 CFR Part 111 to maintain
your individual license. Don't stop
paying your annual fees and complying
with all of your other reporting
requirements, including the trienyell .
Because those -- triennial. Those
requirements are still very much in
place there's just not anything new for
the upcoming triennial and of course
always be checking the continuing
education webpage .
I am aiming for a tempo of a
question of the week. And one of the
reasons why we will not be answering
every single question here today is not
only because of time but for some of the
questions that I think require a little
bit more in-depth answer or I don't know
the answer to it yet, those are the
kinds of things that will be the food for
the question of the week. And we'll
answer to those as frequently as we can
and get them up there for you to review
and absorb.
And if we can move to the next slide,
I think I covered what I needed to
there. Oh, all right.
And here we are at questions.
So I have a list of questions here in
front of me. And so I will just bear
with me one second to review a few of
them.
Okay. There are some really great
questions here. Thank you all so much.
I won't be able to answer all of them
but I will do the very best I can.
One person asks, we are very
interested in how to get our internal
trainings to count for our training
requirements.
Terrific question. Thank you very
much.
We don't have the exact process for
how that is going to work because again,
we need to both select the accreditors
and work with the accreditors. But one
of the things that we are going to work
through with them is how does a company
come to you with their training
requirements and have us have the
accreditors look at them and approve
them for training.
We would like to work with companies
to do that as well as the individuals
who work for those companies.
So that we're only, we meaning the
accreditors, are only looking at the
training once and it applies to
everybody in that company who takes it.
So that it's a little easier for the
people working in the company. They
don't all have to submit something. The
company can submit something on their
behalf. And we will approve at the
company level.
Again, the accreditors will be doing
the approval, not CBP.
Will the NCBFAA CCS that's the
customs specialist certification count
as credit toward the continuing
education requirement? Officially I
cannot say yes or no.
But unofficially because we don't
have our accreditors in place yet, yeah,
I think you can be fairly sure that the
certifications both the CCS and the CES
will count.
We made that assumption in our
economic analysis. And so it would be
-- it would not be to our advantage to
suddenly take that away. We don't want
to do that.
Will the educational opportunities
be available following February 2024?
Yes, when exactly? We don't know. And
of course things like the CES and the
CCS and things that AEEI puts on, those
kinds of things are just going to keep on
happening.
When you need to start taking credit
for them, that will be announced in the
-- that will be announced in the Federal
Register Notice.
If you decide, well, at the
beginning of the 2024 I'm going to take
all these hours even though I don't know
the certain date well, you're only going
to get credit for the date we put
forward and then on.
So just be mindful of that. We
don't want to stop you from doing any
activity that you would normally do and
would enjoy doing and find value from
but if you're trying to front load and
get all 36 credit hours in the month of
February 2024, eh, that probably will
not work.
Will CBP consider continuing
education hours earned if they get it
through other professional
certifications? I'm not going to say yes
or no because I'm not an accreditors.
But I think that is a very interesting
idea. And I hope that you put forth
those credits with one of the
accreditors and see if that will work
for you.
The examples that they gave were
ACSM, APICS, ICPA for of you who get
those professional certifications you
know what those acronyms are, but I
think that's a very -- that's a great
suggestion. And we will definitely keep
it in mind as we move forward. And it
will be one of the things we ask the
accreditors. Thank you very much for
that question.
Just wanted to confirm that the
initial triennial report that's '24 to
'27 is not required to have 36 credits.
The CCS is only required after 2024.
That is what we envision. Because we
know that this is a brand-new program,
we can see the runway ahead of us,
there's a big end of the Fiscal Year in
front of us which is always interesting
for Government activity. We also have
major holidays, Thanksgiving, New Year's,
Christmas, lots of days off.
We are not going to have this in
place by February 2024.
And for that reason we are going to
-- we are going to make the number of
credit hours less than 36. But we don't
know exactly how much less. Because we
aren't quite ready to go yet. That's
why that Federal Register Notice that
announces here are the accreditors and
how many credits you need to take
between now and February 2027, that's a
really important Federal Register Notice.
And that will have all the information
there for you.
That was also one of the reasons
that we -- I don't know if you guys were
paying that much attention to it,
between the final and -- sorry; between
the NPRM and the Final Rule but if you
go back and look at the Proposed Rule,
we originally had 40 and we got a lot of
comments saying, um, why don't you just
make it a credit a month so that's why we
did that is because actually that was
the difference between the ANPRM and the
NPRM that's the third go-around with
this people made the suggestion if you
make it a credit a month that's going to
make -- it's going to make it much easier
to calculate credits and prorate, if you
will, if people come in in the middle
of a triennial period and get their
license, how many credit hours are they
going to need.
You know, we don't want 17.25.
That's ridiculous. We want it to be a
solid number.
That's easy to maintain.
Will the corporate license holder be
required to meet the CE requirements for
their own CE license or are they exempt
fantastic question as the license holder
as the qualifier you're going to need to
do the requirements based on your
individual license, not at the corporate
level but for your own qualifications as
your individual license holder.
Great question.
And I had a couple like that. So
it's on the mind, very, very good.
This is another fantastic question.
Very excited to answer it. Will there be
enough free classes available to amass
the required hours? Yes, we believe so.
And part of that is because the
Government offerings will be free.
Our partner Government agency
offerings will also be free to the
extent they have ever charged. I don't
know for certain they have ever charged
for events. But Government stuff is
usually free and available to
everyone. You just need to sign up.
We are certainly going to be making
sure there's enough content on our
webinars that we have posted to the OTR
website at cp.gov.
The topics just -- at CBP.gov.
The topics just don't get any
simpler. The number of requirements
that the trade has to comply with just
don't ease up. And everything is you
know new laws and new regulations come
forward all the time.
Even if they make things easier or
more streamlined, there's still new
processes and procedures and policies
that we need to follow.
So we think that you will be able to
get education pretty much for free if
that is what you choose to do.
Again, we don't want to take away
from the things that you're doing that
you really have -- you find value in
such as the CCS and CES certifications.
We certainly don't want to downplay any
of that if that's what you like to do
and what you find value in.
But we also want to make sure that
this is attainable for people who are
not part of a large corporation. People
who don't live in a busy city with lots
of opportunities. And for people who
don't have tons and tons of time and
resources to maintain their license.
It has to be attainable for
everyone.
The purpose of this is not to make
it so difficult that people go out of
business or find it too difficult to
maintain their license.
This is intended to further
professionalize your profession and give
greater value to the license that you
hold. Which you work so hard to
obtain.
Will the accreditors charge a fee to
license holders? Another great
question.
Sorry; taking a sip of water.
We are not requiring accreditors to
charge a fee. Nor are we prohibiting
them from charging a fee.
That is one of the things they are
going to have to put in any Request for
Proposal that they give to us.
If somebody comes to us and says,
it's going to take us three weeks to
accredit a course and it's going to cost
$300, that is going to raise some dander
with the CBP reviewers. Because to us
that seems like an awful long time to
review something. And a pretty hefty
fee that a lot of people would not be
able to pay.
So we don't have a ceiling or a
floor for the cost that somebody could
charge. We do anticipate that
accreditors will charge. But we want to
be very careful when we work with them
to make sure that those -- that they are
competitive with one another and not ex
orb at that point to the person who would
be coming to them for a service.
Okay.
Will attendance at trade conferences
be considered as continuing training?
Yeah, I think so.
Again we aren't accreditors but
that's the kind of thing we wouldn't
accredit because it's a Government
activity I'm assuming by trade
conferences you do mean a CBP hosted or
otherwise Government hosted trade
conference if there's things the private
sector puts on then we would want to put
an accreditation with that.
One of the things that we're going
to start doing for conferences that we
put on and other activities that we put
on is working with the Office of Trade
Relations to I'm using air quotes now
brand things that will be good for
continuing education credit. And that
will -- and the number of credits that
we'll have. Sorry.
Sorry about that. My conference
room got raided.
I think that was where I wanted to
end with that one. Yeah, we just need
to make sure that when you attend
something that is CBP hosted, that you
know if it will be eligible for
continuing education credit and how much
credit it will be worth.
What type of proof of training will
be required to be provided with the
triennial report? That is great.
What we are looking at is -- and we
explained this a little bit in the Final
Rule preamble.
We are not looking for you to use a
specific method to track your training.
And we are not looking for specific
formatting for the training, either.
What we are looking to do is modify
e-contribute CBP website to include a
box -- e-CBP website to include a box or
a radio button that you would click and
then say yes I have completed the 36
hours .
Then following that triennial period
we would go through and look at the web
submissions to see -- make sure everybody
checked their box. If you didn't check
your box, then we would contact you and
find out why. And there might be a
perfectly good reason that, oops, I
forgot to check it. That's fine.
We'll work with you on all of that.
And then we are also going to be
working with the broker management
officials at the centers to do some
audits. And not audit with a capital
regulatory audit. But just looking to
see what people were doing. Seeing
what people were -- seeing what
activities people were counting. Again,
the purpose is not to come down on any
individual broker.
The purpose is to look at the kinds
of things you're doing and making sure
that they add value to your license.
If your company has multiple
licensed customs brokers but sign up for
training under one name can all
attendees use that credit or will it only
apply to the person whose name was used
for registration? That's a tricky one
for me to answer off the top of my
head. But we will take that into
consideration. We do understand there's
things like group registration and it's
all under one person. We'll have to make
sure that that -- that the individual
credit follows the actual individual and
gets broken out from the group. So
that's -- I don't have the exact
mechanics of how that would work. But
that was a great question to raise and
we'll think about it going forward.
Thank you very much.
Define proof of training.
I'm not going to. But I'll try to
give you some clues and hints.
Things like a certificate that you
would get at the end of a training,
whether online we would make something
available at the end of the webinar for
here is the certificate for the fact
that you attended this training.
Things like the trade symposia. We
would have a registration -- proof of
registration. Things like that. We
don't want to define it too closely.
Because then we can't be flexible and
you may not -- you may think you have to
do so much when you don't really have to
do all that much.
But that's one of the things we're
going to be working with our partner
Government agencies. With the Office of
Trade Relations. As well as the
accreditors on what types of proof do you
have at the end, whether that's written
proof, electronic proof or paper proof
that you attended these activities.
For training offered by CBP and PGAs
we won't need approval from an
accreditor, correct? Yes, that is
correct. CBP is going to put on their
activities, we are not going to go to an
accreditor to get those approved if you
find value in them that's great if you
don't want to attend that day that's
fine if you can't attend that day and
want to watch the webinar playback at
another time and receive credit for it
that's all fine.
But because we're Government, we
aren't -- we're trying to educate.
We're trying to provide the public as
much -- and you specifically -- as much
information as possible.
So whether or not it was good
training I suppose is debatable but it's
going to be acceptable for continuing
education credit.
If you watched recorded webinars,
how do you show proof we attended?
Great question. That's another
mechanical question that I can't answer
right now but that is one that we have
kicked around. That's something that we
are going to be working out with the
accreditors. When we have them up and
running.
That's pretty important because we
know that that is a lot of what people
are doing now these days especially
because we are -- we are national. So
attending an 8 a.m. webinar on the West
Coast is not a feasible activity and it
would be much more helpful to watch a
playback on that when it's more
convenient for you.
All righty.
We have another question on CCS and
CES.
Because the CCS requires more hours
than this new requirement, can we use
our CCS credit towards our broker
license CE requirement? Again, I cannot
give you the official, no problem. But
that is what we are envisioning.
And we do realize that it's more
hours, quite a few more hours. And it's
good quality education.
So if you are currently a CCS holder
or CES holder or both, this new
requirement is going to be a cinch.
How long do we need to retain proof
of training credit? That is in the Final
Rule. And it's basic record keeping
requirements.
But again, we aren't making it
mandatory that you keep a paper list or a
spreadsheet or use a certain tool.
You can maintain your records in the
manner that works best for you as an
individual.
What about the individuals who are
sitting for the brokers exam in 2023 and
get their license in 2024? So we are
going to consider that you have -- that
you don't have to take any continuing
education training in that first
triennial period where you get your
license in.
So if you sat for the brokers exam
in 2025, passed, got through the
background check. Were awarded your
license. Your first triennial reporting
period that would contain continuing
education would be the one starting in
2027. And the rationale behind that is
that exam is pretty damn hard and you
did a lot of studying for it.
You're pretty current on what's
important and what's needed.
So -- and we know how much you went
through to get your license.
So that's not going to affect a ton
of people but it will affect some so
great question there.
There are a lot of repeat
questions.
Sorry; I'm just finding one that I
haven't answered. I am a licensed
broker but will work for an importer not
a broker and we do not self-file does
the continuing education requirement
apply to me?
Yes, it does. Unless your license
has been suspended, you will need to
meet this requirement.
So how you file, when you file, how
much you file, when the last time you
filed, none of that matters to us. It
is all based on whether or not your
license is active and not in a suspended
state.
Status is maybe a better word.
Suspended status.
What are some of the accreditor
qualification requirements?
That's a great question.
We haven't laid those out in stone
yet. Because we are, again, putting
forth that Request for Information to
make sure we captured what we should be
capturing.
And then the Request for Proposal
will have those criteria defined a lot
more -- laid out a lot more carefully and
clearly. So an accreditor will need to
be able to meet all those requirements
in order to be considered as an
accreditor.
The criteria, the draft criteria,
are laid out in the NPRM. So if you want
to go back and get a sense of what is
probably going to be required or at least
a subset of what is going to be
required, look back at the NPRM. And
that will lay those out for you.
In that list, it does -- that is one
of the things that we do say is that
somebody on the accreditors staff should
have a license. That was one of the
things we laid out. But again those
are just draft criteria, they are not
set in stone. But that does happen to be
one that we put in there in the draft.
Did you mention corporate license
qualifiers aren't subject to the
continuing education requirement I did
not mention that but we were talking
about that earlier so I'll just -- so
I'll reiterate that if you are the
qualifier, the individual who qualifies
for your corporate license yes you as
the individualized license holder will
have to take the continuing education
requirement the corporate license
doesn't have this attachment -- doesn't
have these requirements attached to it
because at the corporate level you're
doing corporate level training for all
the employees and it doesn't pertain to
the individual.
Looking again.
Will there be some sort of portal
where we can review how many credits we
have attained?
We think so.
That is one of the things that we are
looking -- will be one of the criteria
that we put in the RFP.
We think.
Which is are you going to offer a
tool or some sort of online portal that
will allow people to easily track their
hours. Whether or not they take your
education or accreditation or not.
And I think that at least one method
portal tool access point will be
available to you for that.
We were looking for something that
could be put in ACE, as well. That's a
possibility. But probably we're not
going to be able to prioritize that at
least in the short term for CBP.
But we do realize that we put that in
the Final Rule as a possibility. And we
will continue to explore the
feasibility of doing that.
Will some of the old seminars already
posted count towards a credit after the
date is posted on the Federal Register?
No, it's things going forward.
And we are going to make sure that
accreditation is going to be good for a
year. And what that means is that the
people who are providing this education
are making the effort on a yearly basis
to make sure that their content is
fresh, up to date, relevant, conforms
with all laws and regulations that it
should be. And yes, maybe things don't
change all that much on that particular
topic from year to year.
But you know, you would be hard
pressed to find a topic that's like
that.
Everything has new requirements
every year. And regulations come into
place, regulations go away, things like
drawback which are a simplification but
also very complicated.
Things like that just need a yearly
refresher . And of course things like
the Type 86 entries is an ever evolving
topic that always needs new content
behind it and new discussions behind
it.
So watching a webinar from 2019 is
not where we're going.
If there's a good webinar from 2019
that we think could be boosted by a
refresh, we will do that.
But that's a good -- it's a good
tool for us, as well, to make sure that
the content that we have on our website
is current and good and up to date and
refreshed.
Will there be descriptions or
guidelines that the accreditors will be
looking for and approving content? Yeah
I imagine there will be quite a bit and
the accreditors will put together those
guidelines and we'll work with the
accreditors on that the accreditors will
work together.
As -- with us as part of the
development of their services of making
it as clear to the person who is
requesting credit as possible to make
sure that they have checked all the
boxes that they need to. And that they
have provided enough information for the
accreditor to assess the training
materials.
So you know whatever written
materials, written again in wrotetation
marks, it will probably be an electronic
submission, they should be robust. If
it's an actual training course, the
course materials should be part of your
submission.
But again, that's going to come into
greater focus as we move towards the
accreditation process and getting them
up and running.
Credit hours are taken to be taken in
2023 will they be counted towards the
upcoming triennial year no because
there's no yet in the upcoming triennial
year you don't need to follow this
requirement under the 2024 reporting
requirement is over and the notice
comes out that says start your training
now and you will require this many
credits prior to 2027.
Will brokers that have been licensed
over 35 years be required to comply with
the new accreditation rule. Yes we
didn't put any sort of for lack of a
better word age on the training or on the
continuing education hours and
training.
Our requirement is if you have an
active license that's not in a suspended
status.
Has CBP considered how licenses will
be able to view things like the NCSD
seminars from past years and have them
count towards the -- sorry; count towards
the continuing education requirement?
Sorry; that was weirdly worded my bad
not the questioner's bad, my bad.
Yes, those kinds of things are
excellent for continuing education
credit and we'll be working with NCSD to
make sure that those webinars should
stay up and that they are relevant and
if necessary should they be rerecorded
based on new information.
Often those classification webinars
are because of a new requirement or a
new change in the tariff, you need to
redo the webinar. But some of them are
still relevant and we'll make sure that
they are as fresh as possible without
overburdening NCSD to just put a
different shirt on and just say the same
material again. Very good question.
What percentage of the licensed
customs brokers do you intend to audit?
We have not set that percentage in
stone. And it's not set in the
regulations, as well.
Probably -- well, a good chunk of the
number of people that we quote-unqoute
audit won't even know that we audited
them. We will just look to see what you
have done and if it looks good there's
no reason for us to contact you
further.
And again, this is not an audit
that's intended to intimidate or
intended to affect your license in any
way. The purpose of the audit is to
have a conversation.
And if everything you're doing is
fine, that conversation doesn't really
need to be -- it doesn't really need to
take place.
You know if all of your stuff is I've
watched webinars and I've attended the
trade conferences and I went to a port
day, that's all legit.
And we know that those things
occurred.
Um . . .
Will you write an ICP informed
compliance publication on this? We
don't have one in the works yet. Great
suggestion. And we will take that into
consideration.
And see if that would be appropriate
here.
Thank you for the suggestion.
What is the value of each class? Is
one hour counted regardless of the
length of the class? This is actually a
little bit complicated. When you speak
it so I am again going to refer you to
the Final Rule which lays this out what
counts towards what credit and what --
and the length of time that a credit
counts for.
In general it's 1 hour equals 1
credit.
In the Final Rule we went so far as
to do half an hour is half of a credit.
So now you can do things in half credit
increments.
But I don't want to recite something
that is confusing. If you could refer to
the Final Rule and sit there and digest
it, I think it will be clear.
And we will continue -- if we need
to we will answer that question in
writing as a question of the week if a
lot of people are confused. Because I
understand, it's -- it can be a little
confusing.
When will Industry Days were held
for interested accreditors. That's a
good question as we showed you in the
slide presentation we have things that
we're doing in the short term and things
we're doing in a little bit longer
term.
We would like to do industry days,
you know, fairly soon.
However, as I mentioned, the end of
the Fiscal Year is coming up.
And folks that need to help us with
that will have their priorities.
So what I will say is that we are
not going to hold Industry Days as a
time -- at a time that would be
difficult for people to participate.
For example, if the only -- we
finally got all of our ducks in a row
everything is signed everything is ready
to go let's hold Industry Days between
Christmas and New Year's, eh, no, that
would be terrible.
So we would never do something like
that.
We want to make sure that it's as
good a time a year as we can make it
given the holiday season and the end of
the Government's Fiscal Year.
So don't have exact dates. Keep
your eye on CSMS messages. And we will
get that information to you as soon as
possible.
So I am seeing that we are at the 9
minute mark and I'm going to pause here
because it's sort of difficult on a
webinar to interact with folks in this
group.
But I wanted to give either Shari or
Heather the opportunity to speak or
answer a question if they wanted to.
Because I've done a lot of the
talking. I've done most of the
talking. And if they wanted to chime in
anywhere, I would like to give them this
opportunity. Shari, would you like to go
first if you have anything to add or
clarify one of my answers?
>> SHARI McCANN: Hey, thanks,
Elena, I appreciate the opportunity.
Let me just say that there's a host of
questions that have come in, several are
repeats and Elena has covered them.
You know, several are new and I'm
not going to dive into any of those
specifically. But I do want to just
reiterate what Elena and Heather said
that we will be taking from these
questions received and working to
incorporate those (audio cutting in and
out). We really appreciate all the
input (audio cutting in and out). And I
will again refer you for any ongoing
questions today's webinar to the email
that you see on the screen now,
continuingeducation@CBP.division.gov.
With that, you know, Heather or
Omar, if either of you have questions
that you're seeing in the chat that we
should try to cover in our remaining
minutes.
>> OMAR QURESHI: Omar here.
>> HEATHER CHESHIRE: Go ahead,
Omar.
>> OMAR QURESHI: Sorry the audio
cut out a little bit but nothing here
that I don't think we can cover in a
question of the week moving forward on
my end, het are, did you have -- Heather,
did you have anything?
>> HEATHER CHESHIRE: No I just want
to reiterate, we will answer these
questions . There are a lot of
repeats. But we'll get them out in the
question of the week.
So if your question didn't get
answered, not to worry.
>> ELENA RYAN: We'll go ahead to
take the opportunity to introduce Omar
Qureshi who is the new Broker Management
Branch chief I had forgotten to do that
at the top of the presentation I
apologize I'm delighted to work with
Omar and his staff on getting these
requirements up and running as well as
supporting in other areas, welcome,
Omar.
>> OMAR QURESHI: Thanks, Elena and
no worries about that. Just one last
point here, if we didn't get to any one
of your questions that you posed in the
chat that you would like to get answered
sooner rather than later please refer to
the continuing education email box
that's continuingeducation -- one word
-- @CBP.division.gov again
continuingeducation@CBP.division.gov.
It's also right there on your screen.
>> ELENA RYAN: So to close out a
few housekeeping items that we have been
getting right here at the end of the
chat, when will the webinar be posted?
Great question.
We believe it's going to take a week
or two so it's not going to be available
first thing tomorrow. We have to work
through public affairs and we have to
get it all captioned properly. And get
it all 508 compliant before we post it.
But look for it in the coming
weeks.
And it will be when you write to the
continuing education mailbox, I will put
something in there in the response
message that says, hey, it's available
now.
So if you forget about it, you'll
get that reminder, oh, okay, I can go
back and look at this webinar and more
importantly send it out to your broker
friends who weren't able to attend.
And hopefully they will get use out
of it, as well.
All right. So the last piece before
we go today, as we move into the new
Fiscal Year, it's always a little bit
iffy because money and travel is always a
little bit difficult right here at the
beginning of a Fiscal Year.
But Shari, Heather, the rest of the
team, we are looking at putting together
more in-person meetings out with the
local broker associations in the ports.
So that we are able to have closer
one-on-one conversations that we think
are really important to have. Not just
webinars. But to have some
face-to-face and opportunities to
interact with us a little bit less one
way.
I did a lot of the talking. You did
all of the questioning. And it's nice
to have full-on discussions so that's
something we're going to be planning for
the year and coming years ahead. That
was one of the things. We called it a
roadshow back when we did it in 2011 and
2012 when we were trying to get
information from folks on continuing
education and what they thought and
felt. And the Part 111 changes
overall. I found it invaluable and so
did the other people on my team who also
did it.
In-person interactions global
pandemic notwithstanding really, really,
really, really works. And we look
forward to meeting a lot of you in
person and seeing you face to face. And
hearing your stories and answering your
questions a little bit -- in a little bit
more depth than at the national level.
So with that, we shall call it a
webinar.
And thank you all very much for
participating. I will turn it back over
to the host for any concluding remarks.
>> CALENTHIA BANKS: Thank you,
Elena and thank you everyone for joining
us today. We hope you found today's
webinar informative. A reminder that the
continuing education credit code was
placed in the WebEx chat box. And it
will be emailed to everyone within 48
hours. Today's webinar will be posted on
CBP.gov under the trade outreach
webinars in the coming weeks.
We thank you again for joining us.