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CBLE teaching domain

Broker Compliance

Apply licensing, permit, supervision, conduct, and reporting duties under Part 111.

Study unit 1About 8 minutes

Decide when a broker license and permit are required

Ability objective

Distinguish customs business requiring a license from the specific exceptions in Part 111.

Core rule

A person generally needs a customs broker license to transact customs business for others. Section 111.2 lists limited exceptions, including an importer or exporter acting solely on its own account and certain properly supervised broker employees. A national permit issued under §111.19 provides permit authority throughout the customs territory of the United States.

Authority and lookup route

19 CFR 111.2

19 CFR → Part 111 → Subpart A → license requirement and exceptions

Current legal baseline; confirm the edition designated for the exam sitting

Read on CBLE Ace →
Government original ↗
19 CFR 111.11 and 111.19

19 CFR → Part 111 → Subpart B → basic license requirements and national permit

Current legal baseline; confirm the edition designated for the exam sitting

Read on CBLE Ace →
Government original ↗

Reference lookup task

Find the own-account exception and the rule describing the geographic effect of a national permit.

Route: Read §111.2(a)(2)(i), then compare §111.2(b) with §111.19.

Worked example

A U.S. importer prepares and files entries only for merchandise it owns and never acts for another party. Must it obtain a broker license solely for that activity?

  1. 1Identify that the importer acts only for its own account.
  2. 2Locate the general license rule in §111.2(a)(1).
  3. 3Test the facts against the own-account exception in §111.2(a)(2)(i).
  4. 4Keep the exception narrow; acting for another party would change the result.

Conclusion: No, the own-account activity falls within the stated exception, assuming the facts do not extend beyond it.

Common traps

  • ×Extending the own-account exception to affiliated companies automatically.
  • ×Assuming every broker employee must hold an individual license.
  • ×Confusing the individual license with the national permit.
Authority checked: 2026-08-18
Full KnowledgeRelated-category practice
Study unit 2About 9 minutes

Evaluate responsible supervision and control

Ability objective

Use the regulatory factors to evaluate a broker's supervision rather than relying on job title alone.

Core rule

Responsible supervision and control is the degree of oversight necessary to ensure proper customs business. Section 111.28 uses a nonexclusive factor analysis that looks at training, written instructions, volume and type of business, reject rates, employee access to current references, responsiveness to CBP, internal audits, and other evidence of operational control.

Authority and lookup route

19 CFR 111.1 and 111.28

19 CFR → Part 111 → definition, then Subpart C → responsible supervision and control factors

Current legal baseline; confirm the edition designated for the exam sitting

Read on CBLE Ace →
Government original ↗

Reference lookup task

Find three operational factors CBP may consider and confirm that the list is not exclusive.

Route: Open §111.28 and read the factor list as evidence categories, not as a mechanical scorecard.

Worked example

A broker names a licensed officer but provides no training, uses outdated references, has repeated entry rejections, and performs no internal review. Is the officer's title alone enough?

  1. 1Reject job title as the sole measure of actual supervision.
  2. 2Map the facts to training, reference access, rejection rate, and audit factors in §111.28.
  3. 3Consider the factors together and in light of the business volume and type.
  4. 4Conclude that the facts indicate inadequate operational control despite the title.

Conclusion: No. Responsible supervision is evaluated through actual practices and the regulatory factors, not title alone.

Common traps

  • ×Treating the factor list as exhaustive or equally weighted.
  • ×Focusing on a licensed officer while ignoring employee systems and training.
  • ×Assuming low transaction volume eliminates the supervision duty.
Authority checked: 2026-08-18
Full KnowledgeRelated-category practice
Study unit 3About 9 minutes

Handle client funds, correspondence, and compliance advice

Ability objective

Apply the broker's due-diligence, payment, accounting, and client-advice duties to a timeline.

Core rule

Section 111.29 requires due diligence in financial settlements, correspondence, and customs-business filings. Government obligations for which the broker is responsible or has received client funds must be paid by the due date; funds received after that date must be transmitted within 5 working days. Certain client funds require a written accounting within 60 calendar days unless actual payment is made. Section 111.39 separately requires appropriate advice when the broker knows a client is not complying with customs law.

Authority and lookup route

19 CFR 111.29

19 CFR → Part 111 → Subpart C → diligence in correspondence and paying monies

Current legal baseline; confirm the edition designated for the exam sitting

Read on CBLE Ace →
Government original ↗
19 CFR 111.39

19 CFR → Part 111 → Subpart C → advice to client

Current legal baseline; confirm the edition designated for the exam sitting

Read on CBLE Ace →
Government original ↗

Reference lookup task

Find the 5-working-day and 60-calendar-day duties and identify what event starts each period.

Route: Open §111.29(a) and separate government remittance from the written client accounting requirement.

Worked example

A broker receives client funds for an overdue government obligation after the original due date. What timing rule applies to transmission of those funds?

  1. 1Identify that the government obligation is already past due.
  2. 2Use the actual receipt of client funds as the triggering event.
  3. 3Locate the after-due-date rule in §111.29(a).
  4. 4Count the period in working days, not calendar days.

Conclusion: The broker must transmit the funds to the Government within 5 working days after receipt.

Common traps

  • ×Using 60 days for a government remittance that falls under the 5-working-day rule.
  • ×Counting calendar days when the regulation says working days.
  • ×Silently processing known client noncompliance without applying §111.39.
Authority checked: 2026-08-18
Full KnowledgeRelated-category practice
Study unit 4About 10 minutes

Report broker changes and file the triennial status report

Ability objective

Match each broker change to its channel and deadline, then distinguish change reports from the triennial report and education certification.

Core rule

Answer first: address, email, and brokerage-activity-status changes generally require an update within 10 calendar days; specified organization and qualifier changes also require a written report within 10 calendar days, while an approved name or trade-name change must precede use. A triennial status report received during February is timely; failure to file by March 1 suspends the license by operation of law. Filing and paying within 60 calendar days after CBP's notice permits reinstatement; otherwise revocation occurs by operation of law. Beginning with the 2027 report, covered individual brokers also certify continuing-education compliance. The October 2026 exam uses the 2025 Annual CFR; current operational filing instructions remain a separate check.

Authority and lookup route

19 CFR 111.30(a)–(d)

Part 111 → §111.30 → change notices, triennial reporting, suspension, and reinstatement

October 28, 2026 CBLE: Title 19 CFR, 2025 Annual Edition. Check the current eCFR separately for live-law work.

Read on CBLE Ace →
Government original ↗
19 CFR 111.96(d) and 111.101–111.104

Part 111 → triennial fee and continuing-education certification framework

October 28, 2026 CBLE: Title 19 CFR, 2025 Annual Edition. Check the current eCFR separately for live-law work.

Read on CBLE Ace →
Government original ↗

Reference lookup task

Create a trigger matrix for address or email, organization or qualifier, name, triennial report, fee, and continuing education.

Route: Map the triggers to §111.30(a), (b), (c), and (d), then connect §111.96(d) and §§111.101–111.104.

Worked example

An individual broker changes email on August 4 but plans to wait for the next triennial report. Separately, the broker later fails to file during the required February reporting period.

  1. 1Treat the email change as a separate §111.30(a) trigger requiring action within 10 calendar days.
  2. 2Do not postpone the change notice until the triennial report.
  3. 3Treat failure to file by March 1 as suspension by operation of law under §111.30(d)(4).
  4. 4Count the reinstatement period as 60 calendar days from CBP's notice, not automatically from March 1.

Conclusion: The email update is due within 10 calendar days; the missed triennial report follows the separate operation-of-law suspension and notice-based reinstatement rules.

Common traps

  • ×Treating the triennial status report as an annual filing.
  • ×Counting a 10-calendar-day change deadline as 10 working days.
  • ×Counting the 60-day reinstatement period automatically from March 1 instead of CBP's notice.
  • ×Waiting for the triennial report to disclose a change subject to a separate 10-day rule.
Authority checked: 2026-08-18
Full KnowledgeRelated-category practice
Study unit 5About 10 minutes

Separate broker discipline from monetary penalties

Ability objective

Identify the correct ground, sanction path, procedural protections, and appeal route for broker discipline.

Core rule

Answer first: ordinary suspension or revocation grounds are in §111.53, not §111.51; §111.51 addresses cancellation and §111.52 voluntary suspension. A §111.53 disciplinary case generally proceeds through investigation, charges, hearing, decision, and appeal under §§111.55–111.75. Section 111.91 is a separate monetary-penalty path, generally capped at an aggregate $30,000 for a broker and unavailable for the same reason after a suspension or revocation proceeding has been instituted. A missed triennial report follows the operation-of-law path in §111.30(d)(4), not the ordinary hearing path. These are October 2026 exam rules from the 2025 Annual CFR; current-law enforcement work requires a separate current-source check.

Authority and lookup route

19 U.S.C. 1641(b)(6) and 1641(d)

Title 19 U.S.C. → §1641 → penalties and suspension or revocation authority

Official U.S. Code source. For the October 2026 exam, answer from the CBP-designated HTS, CFR, and policy-document editions when they control.

19 CFR 111.51–111.53 and 111.55–111.75

Part 111 → cancellation, voluntary suspension, disciplinary grounds, procedure, decision, and appeal

October 28, 2026 CBLE: Title 19 CFR, 2025 Annual Edition. Check the current eCFR separately for live-law work.

Read on CBLE Ace →
Government original ↗
19 CFR 111.78, 111.81, and 111.91–111.95

Part 111 → reprimand, settlement, monetary-penalty limits, notice, petition, and decision

October 28, 2026 CBLE: Title 19 CFR, 2025 Annual Edition. Check the current eCFR separately for live-law work.

Read on CBLE Ace →
Government original ↗

Reference lookup task

For one alleged violation, identify the §111.53 ground, choose discipline, reprimand, or §111.91 penalty, and trace notice through appeal.

Route: Read §§111.51–111.53 first, then the Subpart D sequence, and finally compare §§111.78 and 111.91–111.95.

Worked example

A corporate broker knowingly files materially false information in its triennial status report. Which path should be analyzed first?

  1. 1Test the false report against the suspension-or-revocation grounds in §111.53(a).
  2. 2Do not cite §111.51, which addresses cancellation rather than disciplinary grounds.
  3. 3If CBP pursues discipline, trace investigation, charges, hearing, decision, and appeal under Subpart D.
  4. 4If considering §111.91 instead, verify its grounds, cap, notice process, and same-reason proceeding limitation.

Conclusion: Analyze §111.53(a) discipline first; neither revocation nor a monetary penalty is automatic, and §111.91 requires its own conditions.

Common traps

  • ×Citing §111.51 as the source of suspension or revocation grounds.
  • ×Assuming every suspension follows a hearing despite operation-of-law provisions.
  • ×Stacking a §111.91 penalty onto a same-reason discipline case without checking the regulatory limitation.
  • ×Treating an allegation as an automatic final sanction without following notice and decision procedures.
Authority checked: 2026-08-18
Full KnowledgeRelated-category practice