Most change in the broker’s sector since ABI ACE deployment schedule , 19CFR111 rewrite proposed broker permit changes, CEE’s Changing Role of the Broker

Challenges-  Dependence on software vendors,  capital investment,  Operational process changes, staff training  lead times from the government side on deployment 18 months?  Non automated partners Opportunities-  increased functionality in operation,  paperless environment  data driven systems in integrate CBP data and broker/importer data bases  better targeting by CBP, lower exam rates  single window, one US Government window, PGA participation  more efficient process changes in operation ACE Deployment

Continuing education,  raises professionalism and license value  some cost in education but value driven to IOR, CBP and the US consumer Permit modernization proposals-  more aligned with remote automated capabilities  benefits for small and large brokers  How does the trade ensure responsible supervision and control under national permit?  `value of the broker license preserved?  IOR Bona fides and brokers  automated approach in ACE controlled by IOR (COAC recommendation)  possible leverage of 5106 data (COAC Recommendation)  how does the broker qualify the identity of the importer (NO COAC recommendation) 19CFR111 Issues ROTB

Unique position in the supply chain  legal agent of importer,  licensed by CBP  should CBP leverage the broker’s relationship with the IOR for compliance?  What liabilities would this cause?  Benefits revenue? What’s in it for broker’s? ROTB in the Supply Chain

Increased CBP enforcement, BIS, Census Exporter more dependent on forwarder for compliance and advanced data filings?(advanced air manifest, other advance data to come) Same automation challenges and opportunities as for ACE in imports? Exporters not used to enforcement Exports

 Managing outside forces: port congestion, vendor dependency- software or otherwise, rapid change in regulations, costs, do our government partners know what we do?  Importers and exporters are our customers- we must deliver value  Leveraging data and document management as value added services  Broker. Forwarder as supply chain specialist  Increased role = increased liability? Increased benefits to broker/ forwarder  Should broker entertain a more leveraged role between CBO and IOR? What benefits? Liabilities? Business Model Wrap Up