Answer first
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
Locate the rule before returning to the facts. Links point to government or official publications.
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A broker names a licensed officer but provides no training, uses outdated references, has repeated entry rejections, and performs no internal review.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?
- 1Reject job title as the sole measure of actual supervision.
- 2Map the facts to training, reference access, rejection rate, and audit factors in §111.28.
- 3Consider the factors together and in light of the business volume and type.
- 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.