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About Us
Carnet Service |
ISF Bonds The Latest
June 21, 2010 Expanding on our ISF STB rejections message below from June 9, 2010, we have asked CBP to clarify “legal designation”, the highest reason for rejection. The Revenue Division explained they are reviewing all ISF STB submissions to ensure the bond principal’s legal designation is listed on the bond form and matches the bond principal’s record presently on file. Bonds issued via Roanoke Trade’s online FastBond™ program (ISF or CBP 301) already print the principal’s legal designation on the bond form. However, FastBond™ cannot guarantee that the bond data matches CBP’s records, so we encourage you to submit a 5106 form along with any ISF STB to help reduce the chance for rejection. June 9,
2010 CBP has recently released statistics on its May 2010 ISF STB submissions, including the top reasons for rejection. During the month, there was an overall 15% rejection rate of ISF bonds, or about one in seven bonds were being rejected. With the centralization of ISF bond processing, there is closer scrutiny of all continuous and single transaction ISF bonds filed with CBP’s Revenue Division. This increased scrutiny has caused more bonds to be rejected due to what some would consider inconsequential mistakes on the bond or its related paperwork. In addition, forgotten rules that may not have been consistently enforced for years by local ports are surfacing as reasons for rejection. Below are the reasons and the frequency when CBP rejected an ISF STB in May, 2010.
Roanoke Trade recommends you read the Revenue Division’s General Instructions for Filing US Customs Bonds to understand their bond filing requirements. While the document mostly pertains to continuous import bonds, the general information provided is useful. We also recommend you utilize Roanoke Trade’s FastBond™ to issue your ISF bonds. FastBond™ performs checks against required fields and keeps data consistent from one form to another to minimize bond rejections. It also assists our customs broker clients with ensuring importers comply with underwriting requirements. Users are notified when an importer is reaching its 5-ISF STB limitation to help avoid disruption in their business. We appreciate your business and are doing all that we can to work with CBP to simplify this process.
March
22, 2010
Roanoke
Trade has received a suggestion from the Revenue Division
(RD) for all parties that file ISF STBs. The most frequent
reason for rejections of an ISF STB is due to the principal
address. Filers are encouraged to submit a CBP Form 5106
along with the ISF STB to avoid this particular rejection.
The RD has advised if a CBP Form 5106 is provided but there
are no changes required, the RD will fill discard the form. March 2,
2010 Roanoke Trade has been advised by the Revenue Division (RD) that they have begun issuing a large number of rejects for ISF STBs this week. Rejections were done via an email that contained general information including multiple reasons for possible rejection. The RD provided the following explanation for rejecting bonds in this manner:
The RD has offered the following advice for those who receive a rejection: “They should look at the specific bond submission that led to the reject (the transaction should be identified in the email subject line) and determine which of the 10 errors cited in the rejection notice applies to their particular bond. (Note: More than one error may apply). They should correct the bond and resubmit it to the Revenue Division. Filers should pay special attention to insure the emails always reflect the unique ISF Transaction number in the subject line; not generic language like “ISF bond” etc.” Roanoke Trade recommends that filers attempt to determine the error of their bond submission and provide corrections to CBP as soon as possible. The RD has stated that they will record non-responses from filers. Should a filer request special consideration at a later date, CBP will factor such non-response information when they move into a more formal, disciplined phase of the ISF program. ISF Bond Form Update The RD has advised Roanoke Trade that an additional field – the ISF Issue Date – is required on the bond form. They agreed to allow us time to program our systems as well as the bond form with this new field, so that should not be the reason for your rejections. We have updated our bond form as quickly as possible and it is now available in FastBond™ for our customers’ use. When issuing new bonds, enter the ISF Issue Date (the date CBP issued the ISF Transaction Number) into the Entry/Effective date field of the Issue Bond screen. If you have received a rejection on an ISF STB and cannot determine the reason for rejection, re-print your bond from FastBond™ and submit to CBP for processing.
01/24/2010 Rich DiNucci, CBP’s Director of Cargo Security Systems and point person on 10+2, updated the trade on an NCBFAA hosted teleconference call the afternoon of January 22, 2010. The update surrounded CBP’s enforcement strategy for 10+2 that is effective January 26, 2010. As pertains to bonding, he stated that they do not intend to issue penalties or liquidated damages for minor, unintentional errors for the first few months; however, they will be evaluating compliance and take action against importers for egregious violations. Also per DiNucci, this ‘graduated enforcement’ does not waive the bonding requirement—he made it clear that bonds are required to be submitted for ISF filings effective January 26th. After concern was expressed about the 6 year open timeframe for when a penalty or liquidated damage claim could be filed against an ISF, DiNucci invited the NCBFAA to submit a proposal for limited timeframes. Roanoke Trade will assist the NCBFAA in drafting this proposal. A concern for our sureties is that CBP does not intend to put any of the above statements in writing. Therefore, there are no guarantees to sureties that absolutely no claims will be issued. CBP technically has the right to modify their position at any time, or to go back years later to file a claim. Roanoke Trade will nonetheless, monitor new information closely and remain as flexible as possible under the circumstances presented. New ISF Bonding Information The week of January 11th, CBP decided to change their position on the bond amount for unified single transaction bonds. It should be calculated at the typical STB bond amount for the entry, plus $10,000; add the $10,000 after determining the STB bond amount for the entry. What to do on the Bonding CBP announced on January 14, 2010 that they will collect under your CBP Form 301 continuous import bond if your ISF bond becomes exhausted (although in the initial months, leniency will be granted as discussed above). Therefore, to control you or your client’s liability, we encourage you to obtain CBP Form 301 continuous import bonds to cover importer security filings. This will also simplify the process and ensure compliance. Finally, remember that Roanoke Trade provides bonds from “A” (excellent) A.M. Best financially rated surety companies and has the latest technology to simplify the bond issuance process. Contact us today and be reassured that we’ll keep you prepared to meet your clients’ needs. FastBond™ ISF Bond Issuance Demonstrations
Customs Brokers Importers Webinar Session: The 411 on 10+2 Bonding
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