1. Trade Support Network ACE Concept Paper June 4, 2002 Millie Gleason Robert Hamilton John Durant

2. Methods of Filing F Traditional Entry Summary –10 Days –Electronic Payment u 10 Days u Monthly Periodic Payment Date F Importer Activity Summary Statement (IASS) –Monthly Filing –Electronic Periodic Payment

3. Periodic Payment System F Commissioner’s Mandate of Revenue Neutrality F 1st-15th: Monies due on 22nd F 16th-End of Month: Monies due on 7th F Netting Payments and Refunds

4. AD/CVD F ACE Will Allow Commerce to Transmit Dumping Orders and Liquidation Instructions and other AD/CVD Case Information Electronically F This Process Will Automatically Suspend All Line Items Identified Within an Order

5. Reconciliation F Flag Whole Entry or Just Specific Line Item F Retroactive Flagging F Issues Include Current Elements as well as Other Elements not Affecting Admissibility F Accounts Will Be Able to View All Flagged Entries and Customs Figures

6. Reconciliation F If Line Item is Flagged for NAFTA, Reconciliation is the ONLY Method of Making Claim F Filers will Have 21 Months to Reconcile Outstanding Issues vs. 15 Currently F Off-Line Spreadsheet No Longer Necessary

7. Elimination of SILs/PEAs F ACE Will Allow Line-Item Corrections of Clerical Errors to be Made Electronically by the Filer Without Customs Involvement F This Will Eliminate Submission of Paper Documents and Quarterly Reporting Requirements

8. Extension/Liquidation F Unless Notified, Account May Assume That Liquidation Will Occur One Year from Date of Summary F Courtesy Notices of Liquidation Will Be Replaced By Account Portal Access F Paper Bulletin Notices Will No Longer Be Posted in Customhouse

9. Extension/Liquidation (Con’t) F ACE Will Perform Extension/Liquidation at Line Item and Summary Level (This Includes IASS and Reconciliation) F No Change Liquidation Under ACE Means That the Monies Deposited by the Account Were Found Acceptable at Date of Liquidation

10. Protests F Current Law Provides for 90 Days from Liquidation for Protest; One Year for Petition F Under ACE, a Six Month Period from Date of Liquidation to File All Protests/Petitions F AFRs Will Be Filed Electronically with Submission of Protest

11. Export of Merchandise F ACE Will Link to AES F Customs Favors a Simplified Drawback Program Based On a Consensus Proposed with the Trade that is MUTUALLY BENEFICIAL F Drawback Refunds Will be Issued by Periodic Statement

12. General Import Profile F 24 Million Entries; $25 Billion F 99% Electronic; 72% Paperless F 460,000 Importers –39% Made a Single Entry –75 % Made 1-9 Entries –5% of Importers = 78% of Entries by Value F By Importer = Top 100 = 33%, Top 1000 = 59%, Top 3000 = 72%

13. IASS IASS (Monthly Entry) Legal Implications Release #1 Release #2 Release #3

14. IASS Design Questions F What is the “Legal Entity”? –Is it 1 Monthly Summary? or –Is it 3 Entries Grouped on a Monthly Basis (like ABI Daily Statement)? F When Do I Have a “Late Entry”? F What is “Extended/Suspended”? F What is “Liquidated”?

15. IASS Design Questions F Customs Currently Extends.7% of the Entries -- What are the “Monthly” Implications? F Customs Will Insist on No “Split” Legal Liability. There are Impacts For: –Brokers –Sureties

16. Proposed Solution F Need Capability for Line Item Extensions/Suspensions/Liquidation F How? In Appropriate Sections Where It Says “Entry” add “or Line Item”

17. Interest Implications F If IASS Must Be Revenue Neutral then Customs Must Know Detailed Release Information BUT, There Must Be a Simpler Way!

18. There Is! 1. Change the Law to “No Interest Due” on IASS OR 2. Change to a Simpler Interest Law, e.g. Average Daily Balance or Mid-Point

19. Deemed Liquidation F ACE Will Liquidate Via “Deemed Liquidation” F Therefore, Your Date of Liquidation Can Be Date of Summary + One Year F Can Be Done if We Change Deemed Liq Law to Read “One Year from Date of Summary” F Other Major Benefit: Far Less Confusing!

20. Protest Proposal F We Believe Protest vs. 520(C) is Confusing and Needs to be Simplified F Customs Proposal: 1. Extend Current 90 Days Protest Period to 180 Days. 2. Trade Off is to Eliminate One Year 520(C) Provision 3. Customs Keeps Current 90 Day “501 Authority” 4. Customs Agrees That “Protest” Involves All Aspects of the Customs “Transaction”

21. AW SHUCKS! WHAT AN HONOR!!!

22. Questions/Comments/Concerns