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Broker Compliance

October 2024 — Question 2

Who must exercise responsible supervision and control over the transaction of customs business of an association or corporation that is a broker?

Why this answer

The cited supervision provision assigns the duty by role: every individual broker must supervise the business they conduct, and for an association or corporation that is a broker, every licensed officer of the entity must exercise responsible supervision and control over its transaction of customs business. The obligation therefore attaches to licensed officers as a class, not to every licensed employee, who may transact business without bearing the entity-level supervision duty, not to unlicensed officers, and not merely to the license or permit qualifiers. Option B tempts because qualifiers anchor the entity's license and permit, but the regulation spreads the supervision obligation across all licensed officers rather than concentrating it in the qualifiers. Watch for: Limiting the supervision duty to license and permit qualifiers rather than every licensed officer.

Original CBLE Simulator explanation — the question and key above are CBP's; this analysis is ours. Verify against the current edition before relying on it in practice.

CBP's cited authority

§ 19 CFR 111.28(a)§ 19 CFR 111.1

Answer and citations as published in CBP's official answer key for the October 2024 examination.

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