Home / October 2024 CBLE / Question 8

An association broker shuts down: who reports where the records are?

October 2024 examBroker ComplianceQuestion 8 of 80

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?

How to get there

The LLC is licensed as an association, and Crimson, Blue and Yellow are all officers holding individual licenses. Each one is responsible. Ownership share and qualifier roles don't change that. The answer is D.

Why the other choices are wrong

A) Only Blue (license qualifier), B) Only Crimson (majority owner) and C) Only Yellow (permit qualifier): § 111.30(e)(3) puts the duty on each licensed officer, not one designated person.
Tip
On termination, “each” licensed person reports: the individual broker (sole proprietorship), each licensed partner (partnership), or each licensed officer (association or corporation).

Source: 19 CFR 111.30(e) (eCFR).

CBP answer key: Answer D · 19 CFR 111.30(e)(3)Source: CBP past exams ↗