CBP Posts "ACE Toolkit" to its Web Site (Part II - Post Summary Corrections, ABI Changes, Reconciliation, Etc.)

CBP states that ESAR will provide ACE enhanced account management functions, a single source for master data, and an integrated account-based, financial and entry summary processing system.

(An article in the Winter 2005 Quarterly NCBFAA Bulletin characterizes some of the upcoming changes as very significant and something that will fundamentally change the way Customs brokers do business. When referring to ESAR A2, one of the ACE Ambassadors quoted in the article notes that the 21st century mandate appears to be "reautomate or perish.")

This is Part II of a multi-part series of summaries on CBP's "ESAR I and II Overview" and highlights CBP's information on ESAR A2 post release business processes. CBP states that the key aspects of the second phase of account enhancements, ESAR A2, include reference data to support A2 and the introduction and/or revision of business processes relating to post release and finance. See ITT's Online Archives or 04/12/06 news, 06041205, for Part I. See future issues of ITT for additional summaries on ESAR II's finance business processes, etc.

(In its February 2006 Modernization Monthly newsletter, CBP stated that the ESAR A1 phase is expected to be active in 2007 and entry summary and revenue processing capabilities will be introduced over the next several years in the A2 and A3 phases. See ITT's Online Archives or 03/03/06 news, 06030315, for BP summary of February newsletter.)

ESAR A2 Post Release Business Processes

According to CBP, the business processes for ESAR A2 post release are as follows:

Post summary corrections instead of SILs and PEAs, etc.. Post summary corrections (PSC) are intended to replace the existing Supplemental Information Letter (SIL) and Post Entry Amendment (PEA) process. The corrections will initially have to be made through the Automated Broker Interface (ABI). The time period allowed for making changes will be up to 183 calendar days from "date of release." The majority of the data elements can be changed during this process with a few exceptions. These transactions will be subject to standard CBP validation and reviews. Changes beyond 183 days, but prior to liquidation, will require a request that the entry summary liquidation be extended for a period of one year. Unlimited corrections will be allowed for clerical errors until the entry summary is scheduled for liquidation. As part of the PSC process, the trade community will need to indicate to CBP specifically which line items are changing and provide the applicable reason code(s) for the core change. CBP also provides the following additional information regarding the PSC process:

can be used to flag entries for reconciliation;

will be subject to Census validations;

must be used to make corrections once the entry summary has been received and the cargo has been released;

will initiate a notification back to the ABI filer if made via the portal

allows query capabilities for historical changes and details to the entry summary made via PSCs (e.g., the source of the change - ABI, Web Portal, or CBP; and

will result in a reply message containing a reason code and possible text if not agreed by CBP.

Streamlined document requests, bar codes on entry summaries, etc. CBP states that it is re-engineering its internal business processes in an effort to collect less paper. The document required processing is a new, streamlined CBP process for requesting documentation from the trade community. As a result, CBP will be using decision making tools to be more effective in its requests for documentation.

Currently, documentation is requested by CBP upon the initial ABI transmission of the entry summary data. As part of ACE, electronic entry summary data will be reviewed by CBP users. If a determination is made that documents are required, ACE will generate a message to the filer. According to CBP, the documentation can take the form of physical paper when technically available, an electronic scanned image (such as a pdf, jpg, etc.)

The addition of bar codes to the entry summary will allow the trade community to query via ABI the date and time for the receipt of the documentation by CBP. Pending issues include (1) the time frames associated with initial request for the documentation and (2) the time allowed for the delivery of those documents.

Trade community correction of Census warnings. The Census Warning Override Process is a new process by which the trade community can electronically correct Census warnings through the submission of an override code for entry summaries prior to or after receiving a Census warning message through ABI.

Flagging of reconciliation codes at entry summary line level, etc. CBP is introducing a new method in the application of reconciliation, which involves the flagging of reconciliation codes at the entry summary line level. Entry summaries would no longer be flagged at the header level. However, if the header of the document is flagged, CBP will apply this reason code to all line items of the document. All unflagged entry summary line items will be liquidated through the normal entry summary due process.

CBP also provides additional information regarding Reconciliation. ACE will leverage account data during its entry summary validation process; ACE will provide the ability to closeout multiple "No Change" underlying entry summaries with a single reconciliation entry summary; and ACE will continue to support aggregate reconciliation processing.

AD/CV Reconciliation prototype. CBP will introduce a prototype or antidumping/countervailing duty (AD/CVD) reconciliation. AD/CVD relevant line items will be flagged for AD/CVD reconciliation.

Once administrative review periods are over and reported to CBP by the Commerce Department, ACE will trigger a request to filers for an AD/CVD reconciliation entry summary number. Once the AD/CVD reconciliation entry summary number is received from the filer, ACE will assign all flagged entry summary line items to this AD/CVD reconciliation document and suspend liquidation while awaiting liquidation instructions from the Commerce Department.

Participation in the AD/CVD reconciliation prototype will be optional. If participation in the prototype is elected, all AD/CVD line items must be processed via the reconciliation model. For reconciliation reason codes, AD/CVD reconciliation and all other reconciliation reasons will be mutually exclusive. For example, a line item cannot be flagged for both value and AD/CVD.

Miscellaneous Changes or Updates. According to CBP, the following are some of the smaller yet important changes that can be expected in ACE:

The ultimate consignee as defined within the CBP 3461 will now be supported at the entry summary line level of the CBP 7501

Temporary Importation Bonds (TIBs) will no longer have to be closed at the originating port is they are completely electronic.

The creation of a CBP 28, 29, or 4647 will initiate a message to the ABI filer as well as the importer of record, via the ACE Secure Data Portal

A new or enhanced entry summary query is being developed to support the addition of new data elements

A new query containing liquidation details is also being developed.

Post Release - ABI Changes. CBP states that an ACE spreadsheet has been generated to track the creation of new ABI transactions and the potential changes to existing transactions. The spreadsheet is intended to provide planning support to members of the trade community as they prepare to enhance and modify their systems, and contains: (1) information about the affected ABI application, the record level, the record identifier, and a notation regarding whether the change would be required during the first deployment of A2, and (2) a brief description of the new or enhanced capability as well as supplemental information with respect to implementation.

CBP notes that an example of a new ABI transaction would be the post summary correction. In this instance, it is estimated that two input records and three output records would be needed to transfer the data between the systems and to handle the new messaging. An example of an enhancement would be the addition of a Census override code or the ultimate consignee at the line level of the Entry Summary (EI) application.

ACE Took Kit available at http://www.cbp.gov/xp/cgov/toolbox/about/modernization/general_info/toolkit/.

CBP's ESAR I & II Overview (dated March 2006) available at http://www.cbp.gov/linkhandler/cgov/toolbox/about/modernization/general_info/toolkit/esar_1_2_overview.ctt/esar_1_2_overview.ppt.

BP Note

It is important to note that CBP's ESAR I and II Overview states that the decisions, policies and solutions in that document are subject to change at any time without prior notice.