An individually licensed customs broker voluntarily suspends her license on September 1, 2024, and reinstates her license on November 15, 2028. How many continuing education credits must she complete during the 2027-2030 triennial reporting period?
How to get there
A broker coming back from voluntary suspension doesn't owe the full 36 credits. The requirement is prorated:
19 CFR 111.102(b)Upon the reinstatement of a license following a period of voluntary suspension …, the number of continuing education credits that an individual broker must complete by the end of the triennial period during which the reinstatement of the license occurred will be calculated on a prorated basis of one continuing education credit for each complete remaining month until the end of the triennial period.
So you need the exact end of the triennial period:
19 CFR 111.1: "Triennial period"A period of three years commencing on February 1, 1985, or on February 1 in any third year thereafter.
The 2027–2030 period runs February 1, 2027 to January 31, 2030. Reinstatement is November 15, 2028, so November 2028 is only a partial month and doesn't count. Count the complete months that remain:
CountingDec 2028 = 1 · Jan–Dec 2029 = 12 · Jan 2030 = 1 → 14 credits
The answer is B.
Why the other choices are wrong
A) 13: you get this if you end the period on December 31, 2029 and forget that it runs through January 31.
C) 27: there are only 14 complete months left in the period after November 15, 2028, so 27 can't come from the correct count. It's there to catch a miscount of the period's end or the reinstatement date.
D) 36: the full requirement. It doesn't apply, because § 111.102(b) expressly prorates after reinstatement.
Trap!
Triennial periods start on February 1, not January 1. Every proration question turns on that last January. Only count complete months, so drop the month of reinstatement unless it starts on the 1st.
Sources: 19 CFR 111.102(a)–(b); 111.1 "Triennial period" (eCFR).
CBP answer key: Answer B · 19 CFR 111.1; 19 CFR 111.102(a)-(b)Source: CBP past exams ↗