CBP Interested in COAC Exam Recommendations, Formalizing Reconciliation Process
CBP Executive Director for Trade Policy and Programs Brandon Lord told an audience during a Commercial Customs Operations Advisory Committee meeting that its work groups had offered "very thoughtful, forward-leaning recommendations," and that he was particularly excited about their new vision of a customs brokers exam.
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During the COAC meeting on June 26 in California, Flexport's Tom Gould, who leads the Next Generation Facilitation Subcommittee, said one thing the Brokers Exam Modernization Working Group was pleased to see was that the pass rates for remote and in-person test takers are now the same.
Lord also praised the Modernized Entry Process Working Group, saying, "I am very pleased to hear that the MEPWG will take a close look at the reconciliation test. That is something, believe it or not, that is very important to me," Lord said.
The ACS Reconciliation Prototype began in 1998, migrated to ACE and was renamed a test, and is still a test today.
"I’m a big believer we can do better," Lord said.
One of COAC's recommendations is that CBP create a process to allow for retroactive flagging of reconciliation entries.
David Corn, COAC trade chair, said the 26 recommendations COAC published ahead of the meeting are meant to start a conversation, as some are "very high level." Corn said members have more ideas for recommendations they didn't release yet, as they still need more fleshing out.
Among the recommendations for CBP that COAC put forward at the meeting:
- Eliminate hand-delivered paper documents such as commercial invoices, transportation documents and export licenses.
- Automate the 520D duty refund filing process.
- Automate the protest filing process.
- Eliminate checks for refunds, such as by helping brokers get electronic bank transfers on behalf of importers.
- Create a searchable database for CSMS messages.
- Create an enhanced message that would allow CBP to communicate PGA holds to truckers.
- Help the Fish and Wildlife Service move away from a paper process.
- Help organize a master partner government agency data set, so that filing redundancies are eliminated.
Corn said that COAC members are keeping an eye on legislation introduced on de minimis, detention and demurrage, the 21st Century Customs Framework, including a new draft on facilitation measures, and renewal of trade preferences for Africa and other developing countries.
He also said that COAC supports the agency's recent enforcement against firms that were not compliant when filing Type 86 entries (see 2405310054). "We support issuing penalties and taking other appropriate punitive measures," he said. "However, CBP must follow established procedures and not compromise the due process rights for not just customer but also carriers, importers and other parties that are in the supply chain." He added that COAC will continue to partner with CBP on electronic clearance for de minimis shipments, something he called "an important evolving space," and said it's important that government and industry are on the same page.