Details of Post Summary Correction Info in ACE FAQ: Courtesy Notices, Etc.

(CBP deployed PSC functionality on June 4, 2011 for type 01 and 03 ACE entry summaries; however, the formal commencement date of PSC is July 25, 2011. Note that the act of filing a PSC constitutes “customs business” as defined in 19 CFR 111.1. In addition, the PSC will replace the existing Post Entry Amendment (PEA) hardcopy process for all ACE entry summaries on September 22, 2011.)

15 FAQs on Post Summary Corrections

The new section on PSC contains the following 15 FAQs:

1. What is a Post Summary Correction (PSC)?

The PSC is essentially a new entry summary version and is a full replacement of the entry summary data, which CBP considers to be the importer's "assertion" that the most recent entry summary data is correct.

2. Can a PSC be submitted for an entry summary which was filed in ACS?

No, PSC is a new ACE process that replaces post entry amendments (PEAs) for all ACE entry summaries.

3. What does the term "PSC filer" refer to?

PSC filer is a new term, as well as a new field within ACE, which can be the same filer as the original entry summary filer or it could be a different filer.

(According to the PSC Guide, if the PSC is filed by someone other than the entry summary filer, ownership of the entry summary moves to the PSC filer.)

4. Will the trade be able submit quarterly PSCs?

No, quarterly submissions are not allowed for ACE entry summaries. All changes to ACE entry summaries must be made electronically.

5. Can a PSC be submitted for an informal (type 11) entry summary?

No, PSCs are not permitted on an informal (type 11) entry summary.

6. Can the importer of record number be changed on an entry summary via PSC?

No, importer of record numbers will not be permitted to be changed via PSC. A list of other additional data elements not permitted to be changed via PSC is available in the ACE ABI CATAIR, which is available here.

(CBP’s PSC Guide also lists other data elements that cannot be changed via a PSC, including (partial list): location of goods, entry filer code, release number, preliminary statement print date, etc.)

7. How many PSCs can be done on one entry summary? Are there any time constraints?

There is no limit to the number of changes that may be submitted. The change is the filer's assertion of the entry summary and will be treated as a full replacement of the entry summary. Changes will be processed as a resubmitted entry summary and will go through the same edits and validations as today.

The filer has a 270-day window from the date that CBP accepted the entry to submit a PSC.

A PSC shall not be accepted, however, if the scheduled liquidation date is within 20 days of the filing. This is to ensure that CBP has adequate time to review and process the changed entry summary information.

8. After the PSC is accepted, do any additional PSCs have to be from the same filer?

No, multiple PSC may be filed by multiple different filers.

9. How does CBP verify that a PSC filing submitted by a broker other than the original broker is appropriate?

The system does not do an edit check on the broker. CBP will assume that the appropriate powers of attorney are on file with regard to the PSC filing.

10. What information is available to me if I am the original filer, but not the PSC filer?

The JB record in the ACE CATAIR document lists the information that is available via the Entry Summary Query; however, only limited entry summary information will be available to you in this situation as the original filer but not the PSC filer. If you are the original filer of the entry summary and the PSC filer, you will have visibility to the full content of the original entry summary information, as well as the new filing.

(CBP’s PSC Guide states that only the PSC filer will be able to view the specific entry summary that was corrected. The filer of the original entry summary will receive an Entry Summary Status Notification (UC) message when a PSC has been filed, but will not have visibility to the new filing. The entry filer will also be able to run an ABI query and view limited information on the entry summary that was corrected.)

11. Right now, even if I don’t file the PSC for my importer, I get an ABI courtesy liquidation notice. Will I continue to get this ABI notice if a different party files the PSC?

There will be a change with PSC. Only the most recent PSC filer will receive the courtesy notice.

(According to CBPs’ PSC Guide, filers under the National Importer Liquidations (NILS) will not be impacted. They will still receive the courtesy notice of liquidation if they have been designated by the importer even if they are NOT the PSC filer. The same is true for filers when the importer has filed a CBP 4811 naming them as the recipient of the bills, refunds, and liquidation notices.)

12. How does the trade know when CBP has completed its review of a PSC?

If the PSC is reviewed and rejected, an Entry Summary Status Notification (UC) message will be sent to the current owner. Otherwise, there is no "completion of review/acceptance" output message available. Use the Entry Summary Query transaction to determine entry summary status.

13. May I claim NAFTA (North American Free Trade Agreement) on a PSC?

No, NAFTA post-importation claims must be made via a 520(d) claim or a protest.

14. Can PSC be filed on an entry that is paid via single payment, e.g., if the PSC was removed from a statement and subsequently paid individually?

Yes, once CBP has received payment on the entry summary, a PSC may be filed, even if the entry summary was paid via "single pay."

15. If I file a PSC as "accelerated liquidation," may I file another subsequent PSC?

No, if accelerated liquidation is requested on a PSC, the entry summary will liquidate in the two-week liquidation cycle, and no additional PSCs may be filed.

FAQs Are Now Divided into 11 Sections

The ACE FAQs document is now divided into the following 11 sections:

• Systems Background

• Automatic Broker Interface (ABI)
• General
• Application
• Cargo Systems Messaging Service
• Carriers--General Information
• e-Manifest Information
• Entry Summary, Accounts, and Revenue
• Periodic Monthly Statement
• Reports
• Post Summary Corrections (New)

TSN Votes to Investigate Issues of Reconciliation in PSC Environment

The Trade Support Network's (TSN)¹ Trade Leadership Committee recently voted that it was worthwhile to investigate whether ACS Reconciliation might be accomplished in an ACE PSC environment. (See ITT's Online Archives or 07/13/11 news, 11071328, for BP’s initial summary of the June 21 webinar where TSN held this vote.)

(According to CBP’s PSC Guide, reconciliation fields such as flagging or unflagging an entry summary are currently not permitted using PSC. In addition, entry summaries cannot be flagged or un-flagged for reconciliation using a PSC.)

¹The TSN is a group of trade representatives who provide input to CBP on the design and development of Modernization projects, such as ACE.

(See ITT's Online Archives or 06/08/11 news, 11060837, for BP summary announcing the availability of CBP's PSC User Guide, which is available here.

See ITT's Online Archives or 06/24/11 news, 11062403, for BP summary of CBP announcing that PEAs will no longer be accepted for ACE entry summaries, effective September 22, 2011.

See ITT's Online Archives or 06/24/11 news, 11062420, for BP summary of CBP's formal notice on the National Customs Automation Program test that allows importers to use the ABI to file PSC of certain pre-liquidation ACE entry summaries (ESAR IV).

See ITT's Online Archives or 03/29/11 news, 11032911, for BP summary of CBP's March 2011 version of the ACE FAQ.)

CSMS #11-000156, dated 07/19/11, announcing the updated FAQ is available here.