CBP Discusses Plans for Single Partnership, Entry, and Financial Account Management Projects

The projects currently being explored are:

• Account Executive Program
• Centers of Expertise (CoE)
• Risk-Based Account Management
• Single Partnership Program
• Simplified Entry Process
• Simplified Financial Processing

CBP emphasizes that the above list of projects has not been finalized or approved by CBP management and that CBP is still in the process of fleshing out its ideas with the help of COAC’s Trade Facilitation Subcommittee.

(See ITT’s Online Archives or 08/27/10 news, 10082714, for BP summary of CBP’s vision for the first three projects -- account executive program, CoE, and risk-based account management -- that were presented at the webinar.)

The following are highlights of CBP’s vision for the remaining three projects -- single partnership program, simplified entry process, and simplified financial processing:

“Single Partnership” Approach for C-TPAT, ISA, FAST, Etc.

CBP states that it is considering a single partnership approach in order to streamline the process through which companies can apply and manage their participation in various CBP trade partnership programs, such as Customs-Trade Partnership Against Terrorism, Importer Self Assessment (ISA), ISA-Public Safety, Free and Secure Trade (FAST), etc. The goals of this project include increased efficiencies through closer connectivity and communication between various CBP partnership programs, decreased cycle time for multiple program approval, etc.

Three alternative models. CBP is considering three different alternatives for single partnership:

C-TPAT Gateway Model - Access to partnership programs would flow through certification in the C-TPAT program. The processing and verification of FAST, ISA, & ISA-PS would be held until C-TPAT certification.

C-TPAT/ISA Unified Model - C-TPAT and ISA would be combined into a single partnership program. Participants would have to be both C-TPAT validated and ISA approved before any benefits would be given out. CBP notes that this alternative has implications involving legislation and mutual recognition agreements (MRAs). According to CBP, COAC rejected this alternative when it was presented.

Open Program Model - The applicant would have the option to join one or any combination of programs. The importer/carrier would select which program(s) to apply on a single application. C-TPAT membership would not be required for ISA. Processing for C-TPAT or ISA approval could start concurrently. C-TPAT and/or ISA would be a prerequisite for derivative programs such as FAST and ISA-PS.

OGA extension. CBP states that it is exploring how CBP can work with Other Government Agencies to facilitate trade. According to CBP, COAC has discussed an extended partnership that which would create “certification” programs with OGAs to facilitate release in conjunction with partnership criteria.

Trusted partners. CBP also discussed partnership recognition, including the definition of trusted partner (i.e., a company that is a C-TPAT tier 2 or tier 3 participant, ISA participant, and meets its financial obligations with CBP).

Simplified Entry Process to Reduce Data Needs

CBP is also considering ways to simplify the entry process in order to reduce the volume and redundancy of data transmissions, reduce post entry queries and amendments, enable statement-based processing for entry summaries and payments, and enable CBP to focus resources on higher risks.

Three concepts under review. Three concepts are under review by CBP:

Unified/concurrent ISF and entry for C-TPAT/ocean -- In this concept, the unified filing of the Importer Security Filing and entry, which is already available, would be augmented to allow CBP to perform cargo selectivity sooner in the process and provide an earlier cargo exam/clearance notification. This project would only be available to C-TPAT partners for ocean shipments only. CBP notes that the cargo would still be subject to exam for OGA admissibility requirements until CBP works out some arrangements with them.

Periodic summary for C-TPAT/ISA -- this concept consists of using the Import Activity Summary Statement (IASS) to allow trusted partners to file entry summary data on a periodic basis (this is already allowed for by 19 USC 1484).

According to CBP, there would be one importer of record for each summary statement. The summary statement would consist of reconfigured entries (i.e., each statement would contain rolled up data, aggregating the value and quantities for common data elements). CBP would be looking to implement this in ACE only and is proposing to make it available to ISA/C-TPAT members essentially as a pilot project. After the pilot, it could be made available to other importers. CBP is not proposing any changes to the entry summary data elements that are currently required. CBP notes that there are still numerous issues related to this concept that would need to be worked out.

Account based release on pre-filed/forecasted info -- This would consist of account based releases utilizing pre-filed or “forecasted” information, with minimal data at cargo release and all remaining data at entry summary. CBP states that the pre-filed information could reside in something like an ACE account profile and might consist of the importer name, address, and other static data elements. The minimal data at release could be manifest data and possibly up to six additional data elements that are necessary for CBP to determine admissibility. There would also be the ISF data. All the remaining data elements would be provided at entry summary time.

Simplified Financial Processing

CBP is considering both short-term and long-term proposals to achieving simplified financial processing.

Three short term proposals. CBP’s three short term proposals include:

ACH application by account - CBP would provide the trade the ability to file an ACH application electronically and to initiate changes via a CBP Web site.

Modernizing the bill form -- CBP would modernize the CBP bill form (CBP Form 6084) by eliminating the carbon-paper and going to a new paper form with a perforated bottom that can be torn off and mailed to CBP in a CBP-provided envelope.

Stale checks - CBP is proposing to post a listing of stale refund checks (checks sent but not cashed) on a CBP website to allow the trade to identify refund payments owed to their company.

Two long term proposals. CBP also has two long-term proposals. According to CBP, these following proposals are long-term because they would require a “heavy lift” from ACE in order to be implemented:

Electronic Periodic eBilling -- Electronic periodic statements for supplemental duty bills would be issued to trade. Payments to CBP would be able to be made via ACH or possibly credit card. The liability for individual bills would be shifted to one periodic (CBP assumes 30 day) bill.

When this is perfected, CBP would then like to turn it into a truly electronic statement and allow the payment of estimated duties and receipt of refunds from CBP. The trade could benefit from the netting effect of such system.

Expanded Periodic Statement -- CBP would extend the number of days in which importers must pay estimated duties by requiring payment within 30 calendar days following the month in which the merchandise is entered. In order to reduce the risk to the government, CBP would also require an increased bond (possibly 20%). CBP is also considering providing an interest bearing escrow account and staggering payment date for each importer. This project would only be available to trusted partners.

CBP is Seeking Input from Trade on These Ideas

CBP states that it wants to get trade input into developing its Management by Account ideas and encourages the trade to submit comments. CBP will soon provide trade associations with written details on its Management by Account projects and seek their input in September 2010.

¹In May 2009, COAC submitted to CBP a white paper to CBP advocating a broad new Account Based Processing (also referred to as Management by Account) concept that would encompass trade compliance, informed compliance, security, intellectual property rights, import product safety, and information technology.

CBP Management by Account presentation available here. CBP webinar recording available here.