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

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business” using criteria that does not lend itself to the ability to advise CBP, in advance,
of the location at which the “paper” documents will be stored. 1
Our members are mindful of the requirement, under 19 C.F.R. §111.25, that these records
“must be made available upon reasonable notice” by an authorized Customs official, at the
district office that submitted the entry, irrespective of where they are located. However, we
believe that the manner in which this requirement is satisfied should be left to the judgment of
the individual licensee. 2
In order to accomplish this result, we ask that you modify the current regulations so as to
require only that the licensee provide the name of the individual, located within the particular
broker district, designated as the “record keeper,” without also requiring the specific location of
the records. Attached, for your consideration, are our suggestions to accomplish this.
We would be pleased to meet with you or representatives of your staff to further discuss
these matters. Please do not hesitate to contact us should further information be required.
Sincerely,
HAI:jov
Enclosures
Harvey A. Isaacs
General Counsel
1 For instance, a broker may choose to keep records relating to a particular customer at the office that is designated
to serve as the “point of contact” for that customer, rather than at a location within the “district.” Because this may
involve storage at several locations for the records relating to a single permitted office, it may be impractical or
burdensome to advise CBP as to the location of a particular record.
2 Given, the fact that documents are routinely placed in storage at remote locations, and the fact that those records
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can be transferred between offices on an “overnight” basis, this would satisfy the requirement that they be
“reasonably” available at the permitted location, although not stored there.