1. Polling Results from the Role of the Broker Webinar
Establishing Bona Fides
June 21, 2012
Note: There were approximately 520 participants in this webinar.
CBP conducted a non-scientific user poll. Results are not statistically valid and cannot be assumed to reflect the views of all webinar participants as a group or the general population. Questions were polled in the order below in four “batches.” Participants could not see vote tallies during polling.
Responses Description
66 Broker that works for a customs brokerage and is neither owner or permit holder
61 Broker that is not the owner but holds the permit for a customs brokerage
37 Broker that owns a customs broker operation
18 Broker that is employed by an importer
17 Importer
15 CBP employee
15 Other
6 Broker that is none of the above
5 Broker that is employed by a customs broker but is implanted in an importer’s office
4 Broker that is an independent consultant
4 Non-broker freight forwarder
1 Broker that is employed by a consulting company
1 Other government employee
250 Total responses
Yes
No Number inside graph indicates number of responses
Would you support including in the regulations elements of “due diligence” with regard to processing of powers of attorney?
154
If you are a broker, is it feasible to always have a copy of the purchase order?
134
If you are a broker, is it feasible to always have a copy of the contract?
113
If you are a broker, is it feasible to always have a copy of the articles of incorporation for a foreign importer of record?
122
If you are a broker, is it feasible to do an internet search to see if the enterprise engages in the exportation of the goods being imported into the U.S.? 90
Page 1

2. No Number inside circle indicates number of responses
Note: CBP conducted a non-scientific user poll. Results are not statistically valid and cannot be assumed to reflect the views of all webinar participants as a group or the general population.
Yes
No Number inside circle indicates number of responses
If you are a broker, can you document written or electronic communication with the importer of record that seeks to determine if they are an owner or purchaser of the goods?
122
If you are a broker and obtain a POA from a third party, is it feasible to always have direct communication with the importer of record?
106
Would you support requiring brokers to get a power of attorney directly from the importer of record and not allowing brokers to get the POA through a third party?
114
If you are a broker, do you validate POAs beyond the guidance provided on the CBP website?
105
If you are a broker, do you or your company have or follow a checklist, standard operating procedure, or guidance manual on validating POAs?
122
If you are a broker, do you validate POAs against the “importer sanctions list” provided on the Department of Commerce website? 87
If you are a broker, do you query ABI (Automated Broker Interface), using the IRS number, to ensure that the importer’s name is the same in CBP’s system as appears on the POA?
104
If you are a broker, do you verify that the address provided by the importer is a valid one? 98
If you are a broker, do you or any of your employees ever complete POAs for importers?
106
Page 2