NCBFAA Seeks Continuing Education Half Credits, Accreditor Self-Certification of Trainings

The National Customs Brokers & Forwarders Association of America remains supportive of CBP's efforts to impose new continuing education requirements for customs brokers (see 2109090030), but requested some changes from the proposed rule in recently submitted comments. The NCBFAA would like to see CBP include provisions for recognizing 30-minute trainings as the smallest unit of continuing education training credits (half credits) and for full credits to include time to allow for breaks. It also said it agreed with CBP's change to 36 hours of education every three years, from 40 hours.

The trade group also asked that CBP "reconsider prohibiting an accreditor from self-certifying its own trainings or educational activities." If the agency has "confidence and trust in approving an entity as an accreditor, it should also enable that party to accredit its own trainings and educational activities. This also will provide an avenue for providers concerned that others will be inspired to create similar programs to maintain a sense of confidentiality until the program is released."

CBP should also give customs brokers more time to respond to notification that the reporting requirements hadn't been satisfied before suspending a broker's license, it said. "In certain cases sending a notification via post to an outdated postal or electronic mail address could substantially delay the customs broker’s ability to respond in a timely and/or adequate fashion," it said. CBP proposed giving 30 days prior to suspension, but the NCBFAA said 60 days is more reasonable "[c]onsidering that a license is at stake." The trade group also said CBP should allow some credits for self-guided learning. Comments on the proposal are due Nov. 9.