CBLE Client Communication and Service 2 — Questions and Answers
Question 1: A customs broker receives a shipment where the importer's purchase order lists a different value than the commercial invoice. What is the broker's best first step?
- File entry using the lower value to minimize duties
- Contact the client immediately to clarify the discrepancy before filing (Correct answer)
- Use the purchase order value as it is the buyer's document
- File entry and note the discrepancy in internal records only
Correct answer: Contact the client immediately to clarify the discrepancy before filing
Brokers must resolve valuation discrepancies with clients before filing to ensure customs entry accuracy and avoid penalties.
Question 2: Which of the following best describes the broker's obligation when a client instructs the broker to misclassify goods to reduce duties?
- Follow client instructions since the client is responsible for accuracy
- Refuse and advise the client of correct classification and legal consequences (Correct answer)
- Classify as instructed but document the client's written request
- Report the client to CBP immediately without further discussion
Correct answer: Refuse and advise the client of correct classification and legal consequences
Customs brokers are legally and ethically obligated to refuse client instructions that would result in fraudulent entries.
Question 3: An importer asks a customs broker to advise on the country of origin marking requirements for imported ceramic mugs. Under which CFR title would the broker primarily research this?
- 19 CFR Part 102
- 19 CFR Part 134 (Correct answer)
- 19 CFR Part 111
- 19 CFR Part 24
Correct answer: 19 CFR Part 134
19 CFR Part 134 governs country of origin marking requirements for imported articles.
Question 4: A client calls demanding release of their cargo but the entry has a CBP hold for examination. What should the broker communicate?
- Promise release within 24 hours to reassure the client
- Explain that CBP holds are outside the broker's control and provide realistic timelines based on exam type (Correct answer)
- Advise the client to contact CBP directly and end the call
- Offer to file a protest immediately to compel release
Correct answer: Explain that CBP holds are outside the broker's control and provide realistic timelines based on exam type
Brokers must set accurate expectations by explaining CBP examination processes and realistic timelines rather than making false promises.
Question 5: Under 19 CFR 111.29, within how many days must a customs broker pay CBP duties collected from a client?
- 5 business days
- 10 business days (Correct answer)
- 15 calendar days
- 30 calendar days
Correct answer: 10 business days
19 CFR 111.29 requires brokers to deposit duties with CBP within 10 business days of receipt from the client.
Question 6: A new client provides a power of attorney but refuses to complete a CBP Form 5106. What should the broker do?
- Proceed without the form since the POA is sufficient
- Advise the client that CBP 5106 is required to establish importer identity before filing entries (Correct answer)
- File entries using the broker's own importer number temporarily
- Request the information verbally and document it internally
Correct answer: Advise the client that CBP 5106 is required to establish importer identity before filing entries
CBP Form 5106 establishes the importer of record's identity and is required before filing entries on behalf of a new importer.
Question 7: A client asks the broker to use a third party's bond for their importation to avoid purchasing their own. What should the broker advise?
- This is permissible as long as the third party consents in writing
- The importer of record must have their own bond or use a broker's bond; using an unrelated third party's bond is not permissible (Correct answer)
- CBP allows shared bonds between related companies only
- Bonds are optional for shipments under $2,500
Correct answer: The importer of record must have their own bond or use a broker's bond; using an unrelated third party's bond is not permissible
Customs bonds must cover the importer of record or the broker acting on their behalf; an unrelated third-party bond cannot satisfy CBP's bond requirement.
CBLE Client Communication and Service 2
A customs broker receives a shipment where the importer's purchase order lists a different value than the commercial invoice.
What is the broker's best first step?