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Call to Action - CBP Bond Insufficiency Notices
January 27, 2009

In the fall of 2008, CBP began using the Business Activity Log (BAL) in the ACE Surety Portal to notify sureties of bonds set to be rendered insufficient due to invalid principal addresses or other reasons. Since CBP believes their efforts resulted in little improvement, they stopped providing the notices.

Resumption of Notification
After encouragement from brokers, surety agents, the Customs Surety Executive Committee (C/SEC) and the COAC Bond Subcommittee - CBP announced today that they will resume bond insufficiency notifications on a trial basis and see whether the trade's response rate improves. Beginning February 3, 2009, CBP will post the notifications to the BAL in the ACE Surety Portal for a one-month trial period (with a possible extension to two months). As such, Roanoke Trade will resume sending these notifications to our clients.

Bonds with Bad Principal Addresses
Within 48 hours of notice from CBP, Roanoke Trade will provide the list of bonds with invalid addresses to the filer. A response must be sent to the Revenue Division within two weeks or the bond may be rendered insufficient.

  1. If the address on file with CBP is correct, the bond principal should send a letter to CBP verifying such, and certifying that they receive mail at that location. This letter should be on the principal's letterhead and signed by an officer of the company (president or vice president). The letter should be faxed to 317-298-1042 or emailed to cbp.bondquestions@dhs.gov.
  2. If the address on file with CBP is not correct, the bond principal or customs broker must file a properly executed CBP5106 and an Address Change Bond Rider. If the principal has more than one continuous bond on file, a rider is required for each. These documents should be faxed to 317-614- 4517 or emailed to cbp.bondquestions@dhs.gov.
  3. If the bond principal no longer requires the bond, the broker may submit a notice of termination to CBP under 113.27(a), or you may ask Roanoke Trade to terminate the bond. The termination notice should be faxed to 317-614-4517 or emailed to cbp.bondquestions@dhs.gov.

When communicating with CBP, your email or fax should reference "Bad Address/Bond Scheduled for Insufficiency" and include the importer number or the customs assigned bond number as well as the date the bond is scheduled to be rendered insufficient. A copy of your communication to CBP should also be forwarded to your Roanoke Trade bond contact. CBP has indicated that as long as there is a response prior to the deadline, it is unlikely there will be a disruption in bond coverage.

Bonds of an Insufficient Amount
The Revenue Division will allow the filer 45 days to file a new bond if CBP determines the amount of the existing bond to be insufficient. The Revenue Division reviews bonds for sufficiency on a monthly basis. As your surety is notified via ACE, Roanoke Trade will advise you and provide assistance in correcting the deficiency. As always, the bond principal will continue to receive their insufficiency notice via mail.

CBP and Roanoke Trade Urge you to Participate
After the one-month trial period, CBP will assess whether their efforts are paying off enough to continue. The Revenue Division is looking for 80% of their notifications to result in resolving bond insufficiencies. Provided this goal is achieved, they will continue their notification efforts permanently.

With the cooperation of our clients during last fall's trial period, our overall client base achieved an above average success rate. Let's continue to partner together in leading the industry - please join us in making this trial period a success!


Roanoke Trade Services, Inc.
Affiliate of Watkins Underwriters at Lloyd's and a Member of Munich Re

phone: 1-800-ROANOKE