CBLE Client Communication and Service 3 — Questions and Answers
Question 1: A long-standing client repeatedly submits incomplete shipping documents, causing entry delays. What is the most professionally appropriate broker response?
- Continue processing without comment to preserve the relationship
- Issue a formal written notice documenting requirements and consequences of incomplete submissions (Correct answer)
- Terminate the client relationship immediately
- File entries based on best guesses to avoid delays
Correct answer: Issue a formal written notice documenting requirements and consequences of incomplete submissions
Professional brokers document recurring document deficiencies in writing to establish clear expectations and protect both parties.
Question 2: Which of the following is NOT typically included in a broker's written fee schedule disclosed to clients?
- Customs examination fees
- ISF filing fees
- CBP duty amounts (Correct answer)
- Merchandise processing fees (MPF) pass-through
Correct answer: CBP duty amounts
CBP duty amounts are government-assessed charges, not broker fees, and are not part of the broker's own fee schedule.
Question 3: A client asks the broker to file a Prior Disclosure with CBP after discovering an underpayment of duties. What is the broker's role in this process?
- Brokers cannot assist with Prior Disclosures; the importer must act alone
- The broker can assist in preparing and filing the Prior Disclosure on behalf of the importer (Correct answer)
- Only CBP attorneys may prepare Prior Disclosures
- Prior Disclosures must be filed within 24 hours so client consultation is unnecessary
Correct answer: The broker can assist in preparing and filing the Prior Disclosure on behalf of the importer
Licensed customs brokers can assist clients in preparing and submitting Prior Disclosures to CBP to mitigate potential penalty exposure.
Question 4: An importer's goods are detained by FDA at the border. The customs broker should:
- File a protest with CBP to override the FDA detention
- Notify the client promptly and advise them to contact their FDA regulatory counsel (Correct answer)
- Request immediate re-exportation without client notification
- Continue the customs entry process as FDA matters are unrelated to the broker's duties
Correct answer: Notify the client promptly and advise them to contact their FDA regulatory counsel
When FDA detains goods, the broker must promptly inform the client and recommend appropriate regulatory counsel since FDA compliance is outside customs broker scope.
Question 5: A client disagrees with a CBP rate advance on a liquidated entry. The broker should advise the client that a protest must be filed within:
- 30 days of liquidation
- 90 days of liquidation
- 180 days of liquidation (Correct answer)
- 1 year of liquidation
Correct answer: 180 days of liquidation
Under 19 USC 1514, a protest must be filed within 180 days of the date of liquidation to challenge CBP's decision.
Question 6: When a broker sends a client a post-entry summary showing final charges, which document typically serves as the formal record of CBP's final duty determination?
- The commercial invoice
- The CF 7501 entry summary
- The liquidation notice (Correct answer)
- The arrival notice
Correct answer: The liquidation notice
The liquidation notice is CBP's official record of the final duty assessment, which may differ from the estimated duties on the entry summary.
Question 7: A broker's client requests copies of all entry documents filed on their behalf. Under 19 CFR 111.23, how long must brokers retain such records?
- 2 years
- 3 years
- 5 years (Correct answer)
- 7 years
Correct answer: 5 years
19 CFR 111.23 requires customs brokers to retain records relating to customs transactions for 5 years from the date of entry.
CBLE Client Communication and Service 3
A long-standing client repeatedly submits incomplete shipping documents, causing entry delays.
What is the most professionally appropriate broker response?