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Form 5106 Blocks 1C and 1D for a division: what goes where?

April 2026 examPractical ExerciseQuestion 25 of 80
Exhibit from CBP's April 2026 exam booklet, PDF page 16
Exhibit from CBP's published April 2026 exam (PDF page 16). Click to enlarge.
Exhibit from CBP's April 2026 exam booklet, PDF page 17
Exhibit from CBP's published April 2026 exam (PDF page 17). Click to enlarge.
Exhibit from CBP's April 2026 exam booklet, PDF page 18
Exhibit from CBP's published April 2026 exam (PDF page 18). Click to enlarge.
Exhibit from CBP's April 2026 exam booklet, PDF page 19
Exhibit from CBP's published April 2026 exam (PDF page 19). Click to enlarge.

If data is required in Blocks 1C and 1D, which of the following choices will correctly identify the data needed to complete those Blocks?

How to get there

Zurefire EV is a division of Zurefire Motor Company. The form's own instructions say Block 1C applies to divisions, and 1D is completed only when 1C is used. The ACE Business Rules spell out what goes in each block for a division request:

So: DIV in 1C and Zurefire Motor Company, the parent, in 1D. That's B.

Why the other choices are wrong

A) Not required, no red asterisk: the instructions make 1C mandatory for a division ("Complete this block if an importer is a division of another company"), whatever the form's asterisks show.
C) DIV + Zurefire EV: the right checkbox, but the division's own name belongs in 1A. Block 1D carries the parent company's legal name.
D) DBA + "Zurefire Motor Company DBA Zurefire EV": Zurefire EV is a division, not a trade name. DBA is for a business operating under another name; DIV is for a separate division with its own suffixed IOR number.
Trap!
For a DIV request, the names flip from what you'd expect: 1A = the division's name, 1D = the parent company's legal name, and 1B = the parent's EIN plus the division suffix.

Sources: CBP Form 5106 instructions (exhibit); ACE Entry Summary Business Rules and Process Document (Trade External v11.0), Chapter 23, "DIV – EIN Division."

CBP answer key: Answer B · CBP Form 5106 Instructions as provided; ACE Business Rules and Process Document (BRPD) Section 23.10Source: CBP past exams ↗