NCBFAA Regular Member Customs Survey

Attachment 2(b)

NCBFAA Regular Member Customs Survey

What is the total number of employees in your firm engaged in customs business work?

Attachment 2(b)

300

200

175

150

300

363

800

Attachment 2(b)

What is the total number of licensed customs brokers employed by your firm?

Attachment 2(b)

3
2

4
1

3
2

1
1

27
1

112

Attachment 2(b)

Does your company have a national permit?

Yes90.8%

No9.2%

In how many customs districts is your firm permitted?

Attachment 2(b)

all

Miami and all remote ports

all

local + national

all

All

National

2 districts

all

National + local

All

National

1 home district + national

Attachment 2(b)

Optional contact information provided by participants

Attachment 2(b)

Grisel Padilla
G. Padilla & Co.

7879772028

Robert Perkins
RLJones.

9199988280

Judy Piercy
E R HAWTHORNE

713 844 8572

Charles Riley
JOHN A STEER

7322058283

Cathy Chafin
Waters Shipping Co

9107638491

Mike Choi
MKC CUSTOMS BROKERS

310-674-7100

Lynnette Keffer
J&K Fresh, LLC

310-419-8770

Raul S Villarreal
PG Customs Brokers

956-790-0010

Luis Martin
Miami International Freight Solutions, LLC

(305)685-0035 x 314

Pat Farrell
export import services

Kevin
Paul Bellak Inc

732-422-1784

Roland Rock
Nippon Express USA, Inc.

847-460-7201

Tom Poche
C J International Inc

5023808400

Mark Sclafani
Nissin Int'l

7187237515

Fred J Ramos Lcb
Airways Freight Corp

800 228 7600

Ilyse Dawicki
Pilot Customs Brokerage Services Corp

Teresa Mccanless
Potts,McCanless & McCanless

713-451-1566

Robert Hornyan
Arizona Customs Brokers

602-273-0912

Scott Larson
MOL Logistics

847-264-1964

Deborah Sadler
Daniel F Young Inc

410-760-1004

David Beja
Beja Custom House Brokers

Dennis Kelly
Thunderbolt Global Logistics LLC

410-633-2722

Julie Moore
rulewave inc

2814477799

Diane Schexnayder
W. R. Zanes & Co. of La., Inc.

504-524-1301

Tom Case
The Camelot Company

847-678-5400

Jack Ryan
Ryan Freight Services, Inc.

817-481-9689

Steve Dew
INTERGLOBAL FORWARDERS

Aquiles Resendez
AQUILES, INC., CHB

956-843-8105

Debbie Meister
Werner Global Logistics U.S. LLC

800-431-7523 X4495

Karen A. Busenburg

Shirley M. Stroupe
Tahoco Logistics Inc

716-874-6286 ext 4226

Laurie Arnold
JAS Forwarding USA Inc

770-688-1206

Kim Host
HOC USA, Inc

716-877-0475

David Corn
Comstock & Theakston, Inc.

201-967-1220 x103

Emily Faulkner (Was Chason)
AIT Customs Brokerage

404-642-7391

Bill Skinner
William B Skinner Inc

201-644-7214

Carol Kreps
OMNITRANS CORP., LTD.

718-995-9220

Dave Bissette
Willson International

716.260.1580

Thayne Worsley
Panalpina, Inc.

Michael J. Rowles
DJR Logistics, Inc.

856-241-9300

Michael Rea
Immediate Customs Service

Marc Greenberg
American Shipping Co. Inc.

201-478-4600

Fred Hall
Fred Hall & Associates, Inc.

9729298236

Lee Connor
John S. Connor, Inc.

4108630211

Richard Zupito
Montgomery Int'l

610-521-1450

Debbie Brule
Global Transportation Svcs

425-207-1492

Mary Frances Allen
Pedraza Customhouse Brokers, Inc.

915-791-5511

Maureen Murray
Dynasty International

617 569 5969

Fernando Torres
GT BROKERS CORP

(305) 629-9240

Charles Santarelli
mersant int'l

347-632-3029

Tom Staub
Interfright Harmonized Log.

1 516 371 0775

Troy Clarke
CBT INTERNATIONAL, INC

5629837211

John Staib
J.E.S.FORWARDING INC.

201-595-0474

April Collier
Pacific Customs Brokers Inc

3603328534

Marty Bloch
Dell Will Customs Brokers

734 946-3040

Melody Sparks
Nankai Transport Int'l

847-629-4748

Marty Dooley
MULTIMODAL INTERNATIONAL, LTD.

847 690 1300

Daniel Zupko
TEAM CUSTOMS BROKERAGE

7048316407

Ron Jacobsen
Northstar Drawback Consultants

Samuel Focarino
Comet Customs Brokers inc

516-398-3704

Bill Wratschko
Customs Clearance Int. Inc

Carie Samuel
Marisol International

417-823-9800

Lorrie Roddy
RF International

630-787-5931

Dave Maurmann
DA Maurmann CHB

4805079489

Crystal Adair
Schenker, Inc.

310-221-3220

Kathy Carlton
KCarlton International

954-792-6505

Jane Taeger
Samuel Shapiro & Company, Inc.

410-539-0540 x290

Karim Fournier
KF LOGISTICS INC

915-859-9066

Rolf Munk
UniGroup Worldwide

6363054147

Eric R. Tonsager
L. D. Tonsager & Sons, Inc.

(503) 907-0670

Venetia Huffman
CV International Inc.

757-466-1170

Merit Tremper
RIM Logistics Ltd

630-595-0610

Gary Ryan
Airport Brokers Corporation

(206) 957-6480

John Mattson
John P Mattson, LCB

3202926450Mark Neumann
Mainfreight International, Inc.

310-761-1511

Darrell Sekin
DJS International Services, Inc.

972-929-8433

Jorge A. Torres
Interlink Trade Services

956-843-9004

Kevin Egan
E. Besler & Co.

847-364-0300

Jackie Mooirng
Smith Air Inc.

281-869-5430

Attachment 2(b)

If you have any additional comments or suggestions regarding this issue, we invite you to share them with our Committee.

1The concept of port specific permitting is outdated in a RLF world.A more centralized approach is needed, while still emphasizing the importance of the role of licensed brokers. Licensed brokers should be required to complete a minimum of continuing education.The CCS designation could be used as the model.It is amazing to think a broker that received their license 20 years ago could be legally operating today without ever having completed any continuing education.

2I am hearing that the issue with the permit could change the requirement that a licensed broker is required for each office.I do not feel a brokerage operation should be able to operate without a licensed broker in each of its offices.Therefore, I feel a permit should be required for each office where customs business is conducted and supervised by a licensed broker.

3I feel that a major change would be a detriment to individual brokers and those that are currently the permit qualifier for their company. Expanding districts would make "responsible supervision" impossible.In the real world of importing, brokers have knowledge not only of Customs regulations but OGA regulations, freight forwarding rules as they relate to imports/exports, technology advances etc.To expand the area a current district license qualifier must oversee would definitely have a negative impact on compliance, and this at a time where there are more rules and regulations changing or added each year.Even if advances in technology and remote filing are considered, the time it takes a compliant broker to properly supervise Customs activity, remain educated on new regulations, and the other various hats worn by most in this business, must be considered.

4"just a comment or a scenario, if we have an employee who works out of her home, telecommuting she will scan her work at her homeand scan and sends herentry work sheets to our office and we would input andwe at the office transmit the entry to Customs thru our computer server.Now, if she moves to out-of-state location because, her husband is re-located, and if she scans her work from her new out-of -state home and sends her scanned work to our office in L A,we hope this would be acceptable to Customs."

5Especially in view of the CEEs being operational, I believe the permitting system needs modification.Sometimes clearing remote does not complete the job; boots on the ground is necessary.The requirement of having a licensed broker employed in each permitted district can be cost prohibitive for the smaller broker.There are many ways modification could be made.I believe, at the minimum, waiving the license in each district should be a benefit to brokers who are validated C-TPAT partners.

6I would love to know what is being proposed as I want to make certain there will not be an adverse impact to our revenue.

7NCBFAA should support retention of the current regulations requiring both District Permits & individual Licensed Customs Brokers to secure each permit. The association's board should remember that by being an individual Licensed Customs Brokers each member was afforded great career opportunities within their respective companies and within the association.Do not allow Customs, transportation integrators, large corporations or small company owners devalue our individual Customs Broker License.

8I feel continuing education is a very important part of any business but I do not feel like it should be up to CBP to govern that education and it should be up to the company owner.

9"I think there are several rules that need to be looked at and revised based on the way Customs Brokerage has evolved, with technology and national permits. Even language on POA's and the option for importers to pay Customs direct, this really isn't an option unless they pay with a late filing or on their own ACH. Local CBP officers still have accessibility to national activity by a broker which I wasn't aware of. I am primarily an RLF broker in the New Orleans district, so my local ports, although many LA,AR,TN, and even MS, these are not the hottest spots for our business mold. So there is a pro & con for Permitting issues."

10Is there a problem with the way they are doing it now?I have no problem.

11"totally support CEU requirements. 40 hours in 2 years is nothing totally support enhancing the brokers role and getting it elevated back to where it was rather than continuing to be a commodity. support CBP with collaboration with NCBFFA establishing guidelines for broker requirements. It should be mutual with CBP getting the bite they want, but also with the input of the NCBFFA representing all size brokers so that everyone is on a level playing field. This is the perfect forum to poll the industry."

12"For the smaller brokers, the mom and pop brokers, changing the overall required number of permits doesn’t represent an issue.They will still be required to obtain at least 1 permit for their company.It is the larger organizations that would benefit from a reduction in the amount of permits required as lowering the number of brokers needed to conduct business could represent significantly less yearly spend on salaries.By reducing the number of permits required, we can expect 2 consequences: A reduction in the quality of ""responsible supervision"" as there will be less active brokers to supervise more employees. A reduction in the demand for brokers in general. By reducing the number of permits, we increase the number of staff actively engaged in ""Customs business"" actually being supervised by permitted Customs Brokers.This will result in less actual quality supervision. The quality of compliance and valuable consultation services to clients will be lowered as there are less people involved who have an demonstrated,committed interest in the industry.Similarly, reducing the number of required permits reduces the demand for licensed Customs Brokers.There will still be the demand for the permit at the small broker, but at the larger corporate broker level, a licensed broker in each district will be eliminated.This reduces the number actual brokers needed in the industry. The overall effect of both of these conditions will be to dilute the valuable services that a committed license broker provides to the importers, degrades the supervision that both USCBP and Importers require, and lowers the value of the broker in general. I am certain that a streamlined procedure can be made through ACE for management, payment and application for permits.This seems to me the logical way to go to improve on the permit process that is in place now.At the same time, I believe that any reduction in the actual number of permits required (using the examples of 1 permit, 9 districts aligned with NCBFAA, or CEEs), is not in the best interest of Licensed Customs Brokers or the industry that we service."

13We are happy with the current requirements for permitting, however we understand the concern of the larger brokerage community, and feel that as long as any new regulation does not put additional requirements on us, we have no problem with reducing the requirement for having a licensed broker in every customs district, to having a licensed broker in each customs region.The overall requirement should be for 'responsible supervision'.Also would not be opposed to that 'responsible supervision' being that for every x number of employees, there must be a licensed individual in a supervisory position over them.

14While supporting the current regulation,when CBP considers waiver from the requirement of license in a district when permitting, should CBP consider supervision and control from other than the licensed office in the geographical district (formerly, the region) when there is day-to-day supervision from a central or other area of the U.S.Or, when supervision "goes to work" from an area outside of this region?What is the difference if the license broker travelling (however far) goes into an office to audit, train or otherwise exercise supervision and control, so long as the mission is accomplished?For reasons of commodities handled in a certain area, personalities and effectiveness, we believe a customs broker knows what's best for supervising its operations.

15"Ok, Confidentially.We had a file where a SEB got misplaced.Customs took the entry without the SEB at the 3461 level.The importer bounced ACH payments on the entry.Customs went to stick him and could not find a copy of the bond.MInd you the entry should never have been processed.I paid a $5000.00 penalty for not having the document.Is that fair? Plus the legal fees which I would have argued to the Supreme Court like Robt. Landweer, except I didn't want the companies name tarnished. Penalty things can easily be settled with a strong letter. While they are at it write a test that tests the applicants not tricks to failure. Get the licenses process down to a regulatory time line. Thanks MJ see ya in Vegas. TC"

16In favor of any plan that maintains or advances the value of an individual customs brokers license.

17"I personally believe a license holder should be in each permited port/office to oversee the customs work. I believe if this is not the case, the value of a licensed customs broker will go down. Companies will not hire and pay for LCB if they are not requried. We are pushing as an industry to requrie continuing education to increase our worth and integrity yet we are looking to take that away but making it uncessary to have a LCB in a permitted port/office? I do not like the idea either of a LCB per so many number of employees or entries. I beleive this is difficult to manage as during the course of a year things change, number of employees can go up and down as well as number of entries. How do you manage that thru the year."

18One National Permit is sufficient.However, in addition to permitting, RLF regulations need to be changed, as RLF brokers are at a disadvantage (1) all entries must be released by via entry summary, which does not allow for port code changes, and (2) RLF brokers cannot must have an IRS# for every entry, in contrast to local brokers having the ability to send name and address on low value shipments.

19I am torn on this issue; I am not sure if eliminating port permitting with a licensed CHB will be good or bad for small brokers (and I have only worked in small CHB companies, so I only have that view)- I tend to think it would actually improve our ability to service the customer, but I don't want it to take away from the fact that we are licensed for a reason and that oversight on a daily basis is key to avoiding recurring errors/issues that may arise from employees that do not know how to look at all the possibilities for clearance matters.I think it would make more sense to rework the RLF process and allow RLF/ACE to accept entries into any port regardless of entry type and where it was filed from to eliminate this permitting issue.

20# of brokers should be per X# of entries.A broker can reasonably supervise X number of entries per month.

21I would suggest setting permit limits as per number of entries filed rather than geographic borders.This allows a smaller company the opportunity to responsibly supervise based on the work actually performed, rather than the burdensome limitation of hiring agents for work that is often close by.

22The current regulations requiring that a Customs Broker be permitted in every district in which it intends to file a local entry needs to be done away with.This is an administrative burden that is wasted in lost time and money and does not benefit us or CBP.Any employee reporting or requirements of supervising license holder in geographic areas where entries are filed, needs to be seperated from the issue concerning whether a permit is on file or not.

23CBP should allow all Nationally Permitted Brokers to clear shipments in any port in the USA regardless of entry type via RLF or if regulations does not permit based on class and kind of merchandise then the broker should be able to file an entry locally at any customs house location in the USA notwithstanding whether that broker has a local permit within that district. Example would be quota merchandise whereas a broker who is nationally permitted could file an entry/entry summary in any port location/customs district regardless of whether that broker has a local permit to perform customs business in that district. The National Permit should replace the need for a local permit. This current restriction is antiquated and is not in sync with current modern CBP practice. If CBP can centralize entry processing via CEE deployment then Customs Brokers should be able to file an entry in any district regardless of entry type as long as they are Nationally Permitted.

24National Permit should be sufficient for any and all districts.

25"I believe that we should only have a National Permit and do away with the local requirements. I also think that we should have a reasonable ratio of licensed brokers to import staff but do not have an idea on what works best.I sometimes believe that through efficiencies, that the larger brokers (i.e. FedEx, UPS, DHL, ANDeringer, Etc), probably have the ability to oversee more staff than a smaller like myself."

26"Eliminating district or geographically determined permits will have a profound impact on the customs brokerage business I believe, especially on smaller brokerage firms. As to whether that impact will be positive or negative is relative to one's view as to what will sustain the viability and necessity of the traditional customs brokerage business model. I believe that removal of geographic-based permitting will lead to large scale consolidation and down-sizing of brokerage firms, which, again, could be a good thing or bad thing depending on your perspective. However, it certainly seems that a change to this process is an inevitability. I know for certain though that the NCBFAA leadership will do their utmost to insure that whatever changes are made will accrue to the benefit of the brokerage community as much as is humanly possible. Thanks as always for standing in the gap and safeguarding the interests of our profession."