Answer first
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
Locate the rule before returning to the facts. Links point to government or official publications.
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?
- 1Identify that the government obligation is already past due.
- 2Use the actual receipt of client funds as the triggering event.
- 3Locate the after-due-date rule in §111.29(a).
- 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.