Customs Committee Agenda for 4/5/07 Meeting - ncbfaa

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________________________________________________________
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 Customs Service
1300 Pennsylvania Avenue, N.W.
Washington, DC 20229
Re:
Proposed Revisions To Customs Broker
“Recordkeeping” Regulations_________
Dear Deputy Commissioner Browning:
This letter sets forth a request by the National Customs Brokers and Forwarder’s
Association of America, Inc., (“NCBFAA”) to approve two much-needed revisions of the current
regulatory requirements relating to recordkeeping requirements for 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 Customs and Border Protection (“CBP”) to maintain the “original” of “entry records” in an
alternative, electronic, format. 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” for a minimum of 120 days
1 We formally 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 formats for 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 for 17 return to Customs custody has been issued, for a