Which ONE of the four choices below correctly identifies how long a customs broker must retain the speficied type of record?
How to get there
Each choice pairs a record type with a retention period, and three of them have the wrong period or the wrong start date. The default rule is 5 years, so look for the record type with its own special rule.
19 CFR 190.15: Drawback recordkeeping… all records which pertain to the filing of a drawback claim … must be retained for 3 years after liquidation of such claims or longer period if required by law …
That's word for word what B says. Drawback is the main exception to the 5-year default.
Why the other choices are wrong
19 CFR 111.23(b): Period of retentionThe records … other than powers of attorney, must be retained for at least 5 years after the date of entry. Powers of attorney must be retained until revoked, and revoked powers of attorney and letters of revocation must be retained for 5 years after the date of revocation or for 5 years after the date the client ceases to be an "active client" …, whichever period is later. When merchandise is withdrawn from a bonded warehouse, records relating to the withdrawal must be retained for 5 years from the date of withdrawal …
A) Entry summary, 3 years after entry: entry records follow the general rule of 5 years from the date of entry (§ 111.23(b); § 163.4(a)).
C) Warehouse withdrawal records, 5 years after entry into the warehouse: the right length but the wrong start date. The clock runs from the date of withdrawal.
D) Revocation letter, 5 years after the POA was executed: also the wrong start date. It runs from the date of revocation, or from when the client stops being an active client, whichever is later.
Trap!
Trap pattern: CBP likes to keep the right length (5 years) and change the trigger date. For retention questions, check both the length and the trigger. A side note: § 163.4(b)(1) words the drawback rule as "the third anniversary of the date of payment of the claim," but this question tracks the § 190.15 wording.
Sources: 19 CFR 190.15; 111.23(b); 163.4(a)–(b) (eCFR).
CBP answer key: Answer B · 19 CFR 163.4(a)-(b); 19 CFR 111.23(a)-(b); 19 CFR 190.15Source: CBP past exams ↗