October 2024 — Question 8
Ms. Crimson and Mr. Blue are both individually licensed customs brokers. They form a Limited Liability Company (LLC) and obtain an organizational customs broker license as an association. The LLC hires Ms. Yellow, who is also a licensed customs broker. Crimson is the majority owner of the LLC. Blue is named as the license qualifier. Yellow is named as the permit qualifier. Crimson, Blue and Yellow are all officers of the LLC. The LLC surrenders its organizational license and permit to the processing Center and terminates the brokerage business. Upon termination, who is responsible for notifying CBP in writing of the name, address, email address, and telephone number of the party having legal custody of the LLC's brokerage records?
- AOnly Blue, as the license qualifier, is required to notify CBP.
- BOnly Crimson, as the majority owner, is required to notify CBP.
- COnly Yellow, as the permit qualifier, is required to notify CBP.
- DCrimson, Blue, and Yellow as individually licensed brokers and officers of the LLC are all required to notify CBP.✓ CBP's answer
Why this answer
The termination provision cited requires, upon the permanent termination of an association or corporate brokerage business, that each officer of the entity who holds an individual broker's license provide written notification to the processing Center of the name, address, email address, and telephone number of the party having legal custody of the brokerage records. Crimson, Blue, and Yellow are all individually licensed brokers and all officers of the LLC, so the duty falls on each of them rather than on any single role-holder. The qualifier-focused options tempt because license and permit qualifiers matter elsewhere in the part, but this notification obligation turns on licensed-officer status, not qualifier designation. Watch for: Assigning the notification duty to one qualifier when every individually licensed officer must notify.
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
Answer and citations as published in CBP's official answer key for the October 2024 examination.
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