At the conclusion of the 2024-to-2027 triennial reporting period, Joe Slacker, a licensed customs broker and part-time college student, completed eight hours of accredited continuing broker education and two semesters of supply chain management college coursework. As a customs broker he was required to complete 20 hours of qualifying continuing broker education. Mr. Slacker submitted a triennial status report, but he failed to report or certify compliance with the continuing broker education requirement. What must Mr. Slacker do to rectify his non-compliance and maintain his license?
How to get there
Mr. Slacker didn't complete the required credits: college coursework isn't accredited CBE, so only 8 qualifying hours count. He also didn't certify. Section 111.104(b) sets out what he must do:
19 CFR 111.104(b)Upon the issuance of such notification, the individual broker must on or before 30 calendar days: (1) Submit a corrected status report … if the individual broker completed the required number of continuing education credits but failed to report and certify …; or (2) Complete the required number of continuing education credits of qualifying continuing broker education and submit a corrected status report … if the individual broker had not completed the required number of continuing education credits at the time the status report was due.
He falls under (b)(2): finish the credits and file a corrected report within 30 calendar days. The answer is C.
Why the other choices are wrong
A) Certify only the 8 hours: (b)(1) is for brokers who completed the requirement. He's short, so certifying 8 hours doesn't fix it.
B) A waiver based on college coursework: Part 111 has no such waiver. Only qualifying CBE counts, meaning government-provided training or training accredited in advance (§ 111.103).
D) Retake the exam within 120 days: 120 days appears in the escalation (if he's suspended, he has 120 days from the suspension order to cure, or the license is revoked, § 111.104(d)), but retaking the exam isn't the remedy.
TipEscalation: notice → 30 calendar days to cure → suspension → 120 calendar days from the suspension order to cure → revocation (without prejudice to a new license application).
Sources: 19 CFR 111.104; 111.103 (eCFR).