polling results from the role of the broker webinar establishing bona fides june 21, 2012 note:...

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ing Results from the Role of the Broker Webinar blishing Bona Fides 21, 2012 Note: There were approximately 520 participants in this webinar. CBP conducted a non-scientific user poll. Results are not statistically valid and cannot be assumed to reflect the views of all webinar participants as a group or the general population. Questions were polled in the order below in four “batches.” Participants could not see vote tallies during polling. Responses Description 66 Broker that works for a customs brokerage and is neither owner or permit holder 61 Broker that is not the owner but holds the permit for a customs brokerage 37 Broker that owns a customs broker operation 18 Broker that is employed by an importer 17 Importer 15 CBP employee 15 Other 6 Broker that is none of the above 5 Broker that is employed by a customs broker but is implanted in an importer’s office 4 Broker that is an independent consultant 4 Non-broker freight forwarder 1 Broker that is employed by a consulting company 1 Other government employee 250 Total responses Would you support including in the regulations elements of “due diligence” with regard to processing of powers of attorney? Ye s No Number inside graph indicates number of responses If you are a broker, is it feasible to always have a copy of the purchase order? If you are a broker, is it feasible to always have a copy of the contract? If you are a broker, is it feasible to always have a copy of the articles of incorporation for a foreign importer of record? If you are a broker, is it feasible to do an internet search to see if the enterprise engages in the exportation of the goods being imported into the U.S.? Page 1 15 4 13 4 11 3 12 2 90

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  • Polling Results from the Role of the Broker WebinarEstablishing Bona FidesJune 21, 2012Note: There were approximately 520 participants in this webinar. CBP conducted a non-scientific user poll. Results are not statistically valid and cannot be assumed to reflect the views of all webinar participants as a group or the general population. Questions were polled in the order below in four batches. Participants could not see vote tallies during polling. ResponsesDescription66Broker that works for a customs brokerage and is neither owner or permit holder61Broker that is not the owner but holds the permit for a customs brokerage37Broker that owns a customs broker operation18Broker that is employed by an importer17Importer15CBP employee15Other6Broker that is none of the above5Broker that is employed by a customs broker but is implanted in an importers office4Broker that is an independent consultant4Non-broker freight forwarder1Broker that is employed by a consulting company 1Other government employee250Total responsesWould you support including in the regulations elements of due diligence with regard to processing of powers of attorney?If you are a broker, is it feasible to always have a copy of the purchase order?If you are a broker, is it feasible to always have a copy of the contract?If you are a broker, is it feasible to always have a copy of the articles of incorporation for a foreign importer of record?If you are a broker, is it feasible to do an internet search to see if the enterprise engages in the exportation of the goods being imported into the U.S.?Page 115413411312290

  • Note: CBP conducted a non-scientific user poll. Results are not statistically valid and cannot be assumed to reflect the views of all webinar participants as a group or the general population.If you are a broker, can you document written or electronic communication with the importer of record that seeks to determine if they are an owner or purchaser of the goods?Page 2If you are a broker and obtain a POA from a third party, is it feasible to always have direct communication with the importer of record?Would you support requiring brokers to get a power of attorney directly from the importer of record and not allowing brokers to get the POA through a third party?If you are a broker, do you validate POAs beyond the guidance provided on the CBP website?If you are a broker, do you validate POAs against the importer sanctions list provided on the Department of Commerce website?If you are a broker, do you query ABI (Automated Broker Interface), using the IRS number, to ensure that the importers name is the same in CBPs system as appears on the POA?If you are a broker, do you verify that the address provided by the importer is a valid one?If you are a broker, do you or any of your employees ever complete POAs for importers?122106114105104If you are a broker, do you or your company have or follow a checklist, standard operating procedure, or guidance manual on validating POAs?1228798106