Jane Smith is a licensed customs broker and a qualifying officer of ABC Broker, Inc. corporation. If ABC Broker, Inc. terminates Jane Smith's employment, which of the following best describes how Jane Smith must report her termination to CBP?
How to get there
The question asks how Jane Smith herself must report. Section 111.28(d) puts the duty on the individual qualifying officer:
19 CFR 111.28(d): Termination of qualifying member or officerIn the case of an individual broker who … is a qualifying officer of an association or corporation for purposes of § 111.11(c)(2), that individual broker must immediately provide written notice to the appropriate Executive Director, Office of Trade, when his employment as a qualifying member or officer terminates and must send a copy of the written notice to the processing Center.
Immediately, in writing, to the Executive Director, with a copy to the processing Center: that's D.
Why the other choices are wrong
A) No obligation; the employer reports it: the corporation does have its own duty to report a change in qualifier within 10 calendar days (§ 111.30(b)(1)). But that doesn't remove Jane's personal duty under § 111.28(d). Both apply.
B) 30 days, to the EAC and the Court of International Trade: the wrong recipients and the wrong deadline. The CIT reviews decisions; it doesn't receive these notices.
C) 30 business days, to the processing Center: the wrong deadline ("immediately"), and the processing Center gets only a copy. The original goes to the Executive Director.
Trap!
Two different "immediately … Executive Director … copy to processing Center" rules sit side by side in § 111.28: (d) termination of a qualifying member or officer, and (e) a change in ownership of a non-publicly-traded broker.
Sources: 19 CFR 111.28(d)–(e); 111.30(b) (eCFR).
CBP answer key: Answer D · 19 CFR 111.28(d)Source: CBP past exams ↗