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<strong>07</strong>0222 v.1.0 ________________________________________________________ Attachment “B” NATIONAL CUSTOMS BROKERS AND FORWARDERS ASSOCIATION OF AMERICA, INC. ________________________________________________________ Office of General Counsel Phone: (212) 944-6611 One Astor Plaza Facsimile: (212) 944-9779 1515 Broadway - 43rd Floor e-mail: hisaacs@tdllp.com New York, N.Y. 10036 October 2, 2003 Douglas M. Browning, Deputy Commissioner United States <strong>Customs</strong> Service 1300 Pennsylvania Avenue, N.W. Washington, DC 20229 Re: Proposed Revisions To <strong>Customs</strong> Broker “Recordkeeping” Regulations_________ Dear Deputy Commissioner Browning: This letter sets <strong>for</strong>th a request by the National <strong>Customs</strong> Brokers and Forwarder’s Association of America, Inc., (“NCBFAA”) to approve two much-needed revisions of the current regulatory requirements relating to recordkeeping requirements <strong>for</strong> licensed customs brokers. 1 Section 163.5(b)(2)(iii), C.R. 2 Pursuant to section 163.5(b)(2), C.R., many of our members have received permission from <strong>Customs</strong> and Border Protection (“CBP”) to maintain the “original” of “entry records” in an alternative, electronic, <strong>for</strong>mat. The approved methods maintain permanent copies of the original documents. In practice, all records relating to a broker’s customs business are filed as the broker receives them and/or at the time the broker files the entry. However, solely because of section 163.5(b)(2)(iii), the broker must keep the original of “entry records” <strong>for</strong> a minimum of 120 days 1 We <strong>for</strong>mally withdraw our letter, dated May 28, 2002, and ask this letter be considered in its stead. 2 Section 163.5(b)(2)(iii) presently provides that, “Except in the case of packing lists (see § 163.4(b)(2)), entry records must be maintained in their original <strong>for</strong>mats <strong>for</strong> a period of 120 calendar days from the end of the release or conditional release period, whichever is later, or, if Page a demand 11 of <strong>for</strong> 17 return to <strong>Customs</strong> custody has been issued, <strong>for</strong> a