2023 October No.34 – Broker Compliance


Which of the following is a violation of 19 CFR 111.41? A non-resident importer has executed a Special Address Notification per 19 CFR 24.36 authorizing the mailing of refunds, bills, or notices of liquidation to its broker.

A) The broker accepts a paper check refund from CBP which is made payable to the importer and mails the check to the non-resident importer.

B) The broker files a drawback entry on behalf of the importer. Subsequently, CBP electronically transfers the drawback refund directly to the importer’s U.S. bank account.

C) The broker files a post-summary correction (PSC) for a refund. Subsequently, CBP mails the broker a paper check payable to the importer. The broker endorses the check, deposits it into its account, and re-invoices the importer for the lesser amount of duties, taxes, and fees.

D) The broker files an entry and pays the duties, taxes, and fees on behalf of the importer. CBP liquidates the entry with a rate advance and the broker receives the bill. Without consulting with the importer, the broker pays the bill and invoices the importer for the amount the broker paid to CBP.

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The Answer is: C

Citation: 19 CFR 111.41
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