ZX Customs Brokers, Inc. (ZX) is a customs broker that is a corporation. George Forest, an individually licensed customs broker, is ZX’s Vice President of Compliance and is the qualifier for ZX’s license and national permit. On May 1, 2025, the Executive Director, Office of Trade, CBP accepts Mr. Forest’s voluntary suspension of his individual license for one year effective May 5, 2025 due to health issues. ZX’s Import Manager, Jayne Smythe, is an individually licensed broker, but she is not a duly appointed officer of ZX. Which of the following statements is FALSE ?
How to get there
George Forest qualified both ZX's license and its national permit. His suspension (effective May 5, 2025) opens two gaps, each with its own clock:
(111.45(a)) If a … corporation fails to have, during any continuous period of 120 days, at least one … officer … who holds a valid individual broker's license … [result:] revocation by operation of law of the license and the national permit … If a broker … fails to employ, during any continuous period of 180 days, a licensed customs broker who is the national permit qualifier … [result:] revocation … of the national permit.
Ms. Smythe is licensed but not an officer. Naming her permit qualifier fixes the permit, but ZX still has no licensed officer. After 120 days (September 2, 2025), the license and the permit are revoked by operation of law. So A ("continue until the permit expires December 31") is FALSE.
Why the other statements are TRUE
Sources: 19 CFR 111.11(c); 111.19; 111.45(a); 111.52 (eCFR).