AN UPDATE ON 10+2/Security Filings
With 10+2 fast approaching, there is no better time than now for you as customs brokers to promote continuous bonds as the economical solution for your importers. CBP has now stated single transaction bonds may be accepted on a case by case basis to satisfy ISF however no formal decision has been made as of yet.
CBP has also not clearly defined specifications for the ‘New ISF Bond”, but did indicate the new bond will be continuous by nature. Now is a good time to advise your importers about the benefits of having a continuous bond moving forward:
- To satisfy normal entry requirements
- To satisfy ISF requirements
- Allow for paperless transactions
- Easy remote filing
As of January 26th 2009 importers must begin 10+2 filing, however penalties for non-compliance will not be issued until 1010. This initial phase was designed to evaluate any difficulties importers will face with compliance. Once 10+2 is in effect, each ISF violation will be equal to $5,000
. Keep in mind, it is not mandatory for custom brokers to carry a bond under their own brokerage name in order to transact security filings. A broker bond can however be used to satisfy ISF requirements. Other bonds that can be used to satisfy ISF requirements include activity codes 1 - 4 (Importer or broker, Custodial or Bonded Warehouse, Int’l Carrier, or FTZ). Before considering using your own bond to satisfy ISF requirements on behalf of your customer, keep in mind CBP will be coming after you (the agent) rather than the importer for the 5,000 penalty. More info regarding the recent updates are available at www.cbp.gov
In the mean time, we suggest attending your local port ISF/10+2 outreach being administered by CBP over the next few weeks to ensure you are apprised of any new developments. http://www.cbp.gov/xp/cgov/trade/trade_outreach/09_outreach_schl.xml We also encourage you as the brokerage and freight forwarding community to submit 10+2/ISF questions to the mailbox below.
CBP will be addressing submitted questions in an upcoming 10+2 FAQ Document to help clarify many industry concerns.Security_Filing_General@cbp.dhs.gov
Once IB&M has more info to share, we will make it available to you.
Thanks as always for your continued support.