CBP Eyeing National Monthly Statements, Line-Level Liquidation Within Simplified Processes Effort

CBP sees additions of national monthly statements and line-level liquidations among the top recommendations within the agency's simplified processes initiative, said Randy Mitchell, director of the Commercial Operations and Entry Division, during a March 24 webinar sponsored by the National Customs Brokers & Forwarders Association of America. National monthly statements, which would consolidate port-specific entry statements into a single statement, would likely be phased in, he said. Line-level liquidation would be a "longer-term" goal due to some "legal and regulatory factors" involved, Mitchell said. Other "top recommendations" include monthly entry summaries and the elimination of the separate 09 entry type for reconciliation by allowing for Post-Summary Corrections instead, he said.

Putting in place national monthly statements would include three phases, Mitchell said. "Each phase would be a version of the Monthly Statement that would include a new feature that accounts for a different type of financial transaction (e.g., bills, refunds, protests, and possibly drawback)," according to Mitchell's presentation. Statutory changes for the 30-day due date requirement would be necessary and are planned for the second phase, according to the presentation. Participation will be optional, he said. "What we are envisioning here, is when you file your entry summary and you're on a national monthly statement," once "that entry summary comes in, we'll provide you back a response message" as a "receipt for what you owed," so the filer will know what will show up on the next national monthly statement, Mitchell said.

Line-level liquidation would allow importers and filers to liquidate entry summaries without waiting for other processes, such as antidumping or countervailing duty reviews, Mitchell said. CBP would like to be able to suspend entry for a single line when necessary, rather than the entire entry at the header level, he said. There's still some major obstacles, including how merchandise processing fees would be handled and other legal requirements, he said. Also uncertain is whether CBP would be able to have two liquidation processes so that filers could choose liquidation by line-level or by entry summary, Mitchell said.

The simplified process effort remains an "unfunded initiative" and CBP is looking to implement these items over about five years, he said. That means the simplified processes won't be "jumping in front of" other changes seen as more pressing, Mitchell said. For example, the addition of house bill of lading release in ACE remains as priority of the agency, though "we don't really have the funds" to address house bill release now, he said. Mitchell noted that national monthly statements was the top recommendation from the Commercial Customs Operations Advisory Committee (COAC) Revenue Modernization Working Group last month (see 1702270016).

The end to the 09 entry type for reconciliation through the use of PSC flagging is another area of consideration at CBP, he said. Under the concept, "filers will flag an entry line for reconciliation which extends the liquidation date an extra year," according to the presentation. "The filer can unflag the entry line during the normal PSC process timeframe within the first year, which will revert the liquidation date back to the one-year mark." There could also be a "mass update" of reconciliation changes made through the PSC process, he said. While software vendors may balk at the idea of having even more reconciliation reprogramming, "let's keep in mind, this is a five-year timeframe that we are looking at."

The use of monthly summaries would allow for thousands of entries to be included within a single summary with an estimate of the duties, taxes and fees owed, he said. That would mean fewer CBP and industry resources used on compliance verification, though that too has several open questions that will be needed to be resolved, he said. A lot of this stuff we still have to work out," Mitchell said. While some pieces are already mostly figured out, "still we're in that pre-decisional stage that we've got to do some more research on our part," including on potential "regulatory, statutory or even system issues." Though it's unclear how these changes will be funded, "we're not sitting on our hands," and the agency is considering alternate funding sources while continuing to plan, Mitchell said.

The simplified processes initiative began in 2011 and numerous recommendations from the trade have already been implemented, such as electronic protests and the ability to see liquidation information online, Mitchell said. Some additional recommendations will be implemented through the next ACE deployment, such as the expansion of reconciliation beyond the 13 designated ports and to the 10 Centers of Excellence and Expertise, he said.

Email ITTNews@warren-news.com for a copy of the presentation.