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.
- 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.
- 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.
- 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