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About Us
Carnet Service |
ISF Bonds The Latest March 2,
2010 Roanoke Trade has been advised by the Revenue Division (RD) that they have begun issuing a large number of rejects for ISF STBs this week. Rejections were done via an email that contained general information including multiple reasons for possible rejection. The RD provided the following explanation for rejecting bonds in this manner:
The RD has offered the following advice for those who receive a rejection: “They should look at the specific bond submission that led to the reject (the transaction should be identified in the email subject line) and determine which of the 10 errors cited in the rejection notice applies to their particular bond. (Note: More than one error may apply). They should correct the bond and resubmit it to the Revenue Division. Filers should pay special attention to insure the emails always reflect the unique ISF Transaction number in the subject line; not generic language like “ISF bond” etc.” Roanoke Trade recommends that filers attempt to determine the error of their bond submission and provide corrections to CBP as soon as possible. The RD has stated that they will record non-responses from filers. Should a filer request special consideration at a later date, CBP will factor such non-response information when they move into a more formal, disciplined phase of the ISF program. ISF Bond Form Update The RD has advised Roanoke Trade that an additional field – the ISF Issue Date – is required on the bond form. They agreed to allow us time to program our systems as well as the bond form with this new field, so that should not be the reason for your rejections. We have updated our bond form as quickly as possible and it is now available in FastBond™ for our customers’ use. When issuing new bonds, enter the ISF Issue Date (the date CBP issued the ISF Transaction Number) into the Entry/Effective date field of the Issue Bond screen. If you have received a rejection on an ISF STB and cannot determine the reason for rejection, re-print your bond from FastBond™ and submit to CBP for processing.
01/24/2010 Rich DiNucci, CBP’s Director of cargo security systems and point person on 10+2, updated the trade on an NCBFAA hosted teleconference call the afternoon of January 22, 2010. The update surrounded CBP’s enforcement strategy for 10+2 that is effective January 26, 2010. As pertains to bonding, he stated that they do not intend to issue penalties or liquidated damages for minor, unintentional errors for the first few months; however, they will be evaluating compliance and take action against importers for egregious violations. Also per DiNucci, this ‘graduated enforcement’ does not waive the bonding requirement—he made it clear that bonds are required to be submitted for ISF filings effective January 26th. After concern was expressed about the 6 year open timeframe for when a penalty or liquidated damage claim could be filed against an ISF, DiNucci invited the NCBFAA to submit a proposal for limited timeframes. Roanoke Trade will assist the NCBFAA in drafting this proposal. A concern for our sureties is that CBP does not intend to put any of the above statements in writing. Therefore, there are no guarantees to sureties that absolutely no claims will be issued. CBP technically has the right to modify their position at any time, or to go back years later to file a claim. Roanoke Trade will nonetheless, monitor new information closely and remain as flexible as possible under the circumstances presented. New ISF Bonding Information The week of January 11th, CBP decided to change their position on the bond amount for unified single transaction bonds. It should be calculated at the typical STB bond amount for the entry, plus $10,000; add the $10,000 after determining the STB bond amount for the entry. What to do on the Bonding CBP announced on January 14, 2010 that they will collect under your CBP Form 301 continuous import bond if your ISF bond becomes exhausted (although in the initial months, leniency will be granted as discussed above). Therefore, to control you or your client’s liability, we encourage you to obtain CBP Form 301 continuous import bonds to cover importer security filings. This will also simplify the process and ensure compliance. Finally, remember that Roanoke Trade provides bonds from “A” (excellent) A.M. Best financially rated surety companies and has the latest technology to simplify the bond issuance process. Contact us today and be reassured that we’ll keep you prepared to meet your clients’ needs. FastBondTM ISF Bond Issuance Demonstrations
Customs Brokers Importers Webinar Session: The 411 on 10+2 Bonding
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