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Important Bond and ISF Updates
January 6, 2011

Following are some important bond updates worth noting as we enter the new year. For more information, please contact your Roanoke Trade bond representative, or email us at fastbond@roanoketrade.com.

CBP Prefers Bonds Sent via Email - Incoming and Outgoing
 On November 23, 2010, CBP posted a revised document of polices and procedures for bond filings. In it, CBP expressed their preference to receive bond submissions via email, rather than by fax or U.S. mail. Also, if the filer provides the bond principal's email address in the bond submission, CBP states it will email a copy of the approved bond directly to the principal in as little as 5 days.

Roanoke Trade encourages all filers to include the bond principal's email address. Such information will reduce potential bad address situations whereby CBP renders the bond insufficient until the principal's address is clarified, as well as deliver the bond copy to the right person.

For more information, please review CBP's Latest Policies & Procedures document.

CBP Creates New Email Subject Line for Rejections
 In CBP's latest policies and procedures mentioned above, they ask for all submissions in response to a rejected electronic bond (e.g., an ISF single transaction bond) to utilize "Reject Electronic" in the email subject line. Filers should continue to include the importer number and part of the principal name in the subject line, such as: REJECT ELECTRONIC: 12-345678900 ABC IMPORTERS.

CBP Clarifies Language in Current Bond Formulas Document
 On January 4, 2011, CBP posted a revised bond formula document explaining how continuous import bond amounts are determined and reviewed for sufficiency. This process is the primary reason CBP issues notices of bond insufficiency to importers. The revised document did not change any existing practice, but it was reworded to provide better clarity for the trade. While some formulas include special consideration for antidumping duties for certain agriculture/aquaculture products, CBP has not been applying those calculations for some time, and CBP does not plan to anytime soon.

CBP Reminds U.S. Virgin Islands Importers of Need for Bond Rider
 During the last week of December, CBP reminded the trade that continuous bonds securing entries and importations at U.S. Virgin Islands ports require a special bond rider. Because of some technicalities in how "port" and "port of entry" are defined in the CBP regulations, U.S. Virgin Islands ports are specifically excluded. The rider serves to include activity at USVI ports to be within the scope of the bond and allow importers to use their bonds at USVI ports in the same manner they do throughout all other CBP ports.

Only importers whose bonds have been used for USVI import activity, or those importers that may do so in the future, will need to have the rider on file with CBP. Nearly all importers will never need this rider. Roanoke Trade has contacted those affected by this requirement and will continually monitor future import activity should new importers or bonds require the rider.

Bonded Carriers Urged to Establish an ACE Portal Account
 The planned early 2011 deployment of e-Manifest functions in ACE will allow a carrier to designate those trade partners authorized to obligate the carrier's type 2 custodial bond for in-bond movement of cargo. A carrier needs to establish his ACE Portal Account and have his continuous bond linked to his account by his SCAC and Importer Number. Once a carrier establishes the parties authorized to obligate his bond, CBP will enforce those authorizations. For carriers that do not establish and manage those relationships in ACE, any party will be authorized to obligate the carrier's bond.

For more information, please review CBP's CSMS Message. You may need to scroll through the list until you find the message number.

English: Message 10-000260

Spanish: Message 10-000261

ISF Changes to Take Effect January 23, 2011
 CBP intends to update its software rules for Importer Security Filings (ISF) effective January 23, 2011. Many of these changes were announced in CBP's latest ISF FAQ update posted on their website in July, 2010. Some changes of note involve the expansion of codes describing the type of submission and type of shipment:

  1. New codes involve the ability to tell CBP the ISF submission is being filed late and will not be secured by a bond. CBP cautions the trade that the use of this code should be rare and infrequent. Also its use can cause the cargo to be subject to significantly stringent security measures including examination requirements that can mean delays and extra expenses.
  2. Other codes tell CBP that an existing ISF-10 filing (for goods entering the U.S.) is changing to an ISF-5 (used for in-bond or transit cargo), and vice versa.
  3. CBP expands the codes for the type of shipment by creating a new category for informal shipments. When an informal shipment is identified, CBP requires additional information regarding the goods, including the estimated value, estimated quantity, weight, etc.

Please review CSMS Messages 10-000246, 10-000249, and 10-000269 that can be found by paging through the list of messages.


Roanoke Trade Services, Inc.
phone: 1-800-ROANOKE