|2012 NCBFAA Annual Report
By Darrell Sekin, Jr.
My first year as NCBFAA president has been quite an eye opener. From the very first week after my election at the 2012 Annual Conference I hit the ground running and haven’t stopped yet. I think I know how Forrest Gump felt. One thing that continues to impress me is the level of commitment of all of the volunteers who give so much time and effort to make our industry better.
We have had many challenges this year from governmental agencies, Congress, port work stoppages and many other areas that we deal with daily. These challenges have been taken on by our Committee Chairs and the Committee and Sub-Committee members. Everything from membership and By-Laws to Annual Conference and Drawback has a group of dedicated individuals working to make things happen.
The Transportation Committee has been very active this year under the leadership of Jan Fields. The year started out with a meeting at the Federal Maritime Commission (FMC). The meeting included an invitation from Chairman Fields to the FMC Chairman to engage with the Committee at our Fall Government Affairs Conference (GAC). What evolved from this was a Transportation Committee meeting day at the GAC that involved various governmental agencies coming in to sit with the Committee to discuss various initiatives and listen to our Committee members’ concerns about those initiatives. It included representatives from FMC, Customs and Border Protection (CBP) and Transportation Security Administration (TSA). It was a very successful meeting and set the tone for future such meetings.
The Transportation Committee also had its hands full this year in dealing with the roll out of the ACE M1 in bond. This was an undertaking that, without the persistence and oversight of our Committee, could have ended in a disaster as our members helped bridge the gap between government and the carriers and helped everyone understand what had to happen to keep cargo flowing.
Another major area of involvement for the Transportation Committee was on the Federal Motor Carrier Safety Act, which, if implemented as original legislation had intended, would have meant licensing and bonding requirements for all of us just to arrange delivery of a client’s cargo from the local airport or pier to the customer’s dock across town. We were able, through the help of our legislative counsel, to get this changed. Rounding out the year, the Committee was preparing to take on a Notice of Proposed Rulemaking issued by the FMC requiring higher bonding for licensees and also a license renewal requirement every three years. Stay tuned for more on this issue in 2013.
Under the leadership of Mary Jo Muoio, the Customs Committee seems to be in constant motion. One of the more prominent issues this year has been the "Role of the Broker" discussions. As just about anyone who can spell the word broker knows, CBP conducted a nationwide series of town hall meetings. This started roughly two years ago with an NCBFAA Sub-Committee and CBP as a discussion on a re-write of Section 111 of the regulations. Simultaneously, there were discussions about what or how CBP envisioned leveraging the customs broker and where we saw our role in all this. The two discussions eventually morphed into the one discussion of "Role of the Broker" and sought input from just about everyone and anyone who knows what a customs broker is. It is gratifying that so many members of the customs brokerage community attended the town hall meetings and gave input into the process. Because it is about us, we needed to be heard. Any regulatory changes appear to still be at least a year out, so stay tuned for further opportunities to comment on this important issue.
Somewhat analogous to the "Role of the Broker" project, we were challenged at last year’s Annual Conference by then CBP Deputy Commissioner Thomas S. Winkowski to lay out our vision of where we saw the customs broker in the future. To this end we spent many hours putting together our paper entitled "The Customs Broker Today and Tomorrow" to help frame our discussions on this subject with CBP.
The other main area of on-going focus for the Customs Committee has been the continued progress on ACE. Rest assured this train is coming down the track. We continue our involvement to make sure that the system is functional and has the edits needed in the system for the customs brokerage community, which processes more than 95 percent of all entries filed with CBP.
Under Chairman Ken Bargteil and Director Federico Zuniga, our National Customs Broker and Forwarder Association of America, Inc., Educational Institute (NEI) is an increasingly important area not only to our membership but also to anyone involved in importing or exporting. Laws and regulations are changing daily and more and more is expected of our industry. The only way to keep up with the rapidly changing environment is to have some form of continuing education. In as much as we would all like to say that we attained our license and that is all that is needed, it simply is not enough. Anyone who has had a visit from their local CBP office for a friendly broker visit knows that one of the first things they are looking for is what training have you done for your staff.
Likewise, our customers have high expectations of our keeping abreast of changes in regulation and business practices. It is difficult for any one of us to do this on our own, particularly those of us with smaller shops. However, as an industry we can and have developed a quality continuing education program that is both affordable and flexible. Industry professionals can get all of their continuing education points each year for free, without ever leaving their offices if they so choose through various programs offered by the NEI.
As I look forward to year two of my tenure, I have little doubt that the challenges of my first year will carry over and that I will continue to be fully engaged in meeting not only the old ones but also the new ones that will appear. But regardless of what is expected of me, I will continue to do everything possible to serve our membership to the best of my abilities.
Executive Vice President’s Report
By barbara reilly
As most of you know, NCBFAA represents 800 plus freight forwarders, customs brokers, ocean transportation intermediaries (OTIs), NVOCCs and air cargo agents, serving 250,000 importers and exporters. Our members’ more than 100,000 employees manage international cargo across the United States and in every authorized country around the world.
Under the oversight of our Volunteer Leaders, most of whom are elected locally and nationally, the NCBFAA is currently celebrating its 115th year of remaining "The Voice of the Industry," and one of the oldest trade organizations to represent the international trade arena in the world. As the premier source of learning, knowledge and future-oriented human capital for the industry, we provide not only top notch education through the ever growing NEI, but ideas and advocacy that contribute substantially to the professionalism of the international cargo community.
In a White House ceremony, where the U.S. Department of Commerce (DOC) Secretary John Bryson, in his final public appearance, recognized the effectiveness of the NCBFAA’s contribution to the industry by awarding the Association its coveted Presidential "E" Award for Exports. The "E" Awards are the highest recognition any U.S. entity may receive for making a significant contribution to the expansion of U.S. exports, since they began under President John F Kennedy.
U.S. companies are nominated for the "E" Awards through the U.S. Commercial Service office network in 108 U.S. cities and more than 75 countries which helps U.S. companies to export. The primary criterion for the "E" Award is four years of successive export growth or of supporting the export growth of others. "E" Awards are awarded to applicants that can demonstrate a significant contribution to U.S. export expansion that is measurable, innovative, sustainable, and has broad impact.
"Exports continue to contribute vitally to the fundamental growth of America’s GNP and the NCBFAA’s membership is a prime mover in that growth," said NCBFAA Chairman of the Board Jeffrey Coppersmith, who was on hand to receive the award. "Our Association is extremely proud of this recognition and on behalf of our members around the country, and those who set up the foundation of our organization over 115 years ago, I thank our federal regulatory agency partners at the Department of Commerce for this acknowledgement of our role in the international trade and commerce arena."
"I am pleased to recognize NCBFAA for receiving the President’s ‘E’ Award which honors companies that provide momentous assistance towards increasing U.S. exports," said Secretary Bryson. "This Administration is committed to leveling the playing field for American businesses and workers to help U.S. companies build things here and sell them around the world. ‘E’ Award winners like NCBFAA have excelled in this effort, demonstrating four years of successive export services growth. It is organizations like this that are helping to grow our economy and put more Americans back to work."
Throughout the years, for example, NCBFAA has worked closely with the DOC in not only finding participants for the U.S. Export Pavilion NCBFAA kiosk that travels to various convention locations nationwide with the assistance of numerous member volunteers, but also in arranging a variety of diverse, timely and informative educational offerings throughout the country. Whether these meetings, roundtables or seminars are coordinated through our various Affiliated Associations, or directly through the different DOC agency partners that include Census, BIS, AES, and ITA to name a few, NCBFAA supports DOC's outreach and educational initiatives. It's another way in which the Association goes beyond its charter to inform industry participants on issues of importance to them.
Other examples include
- NCBFAA’s Chairman Jeffrey Coppersmith’s appearance in a two-part video describing the work of the freight forwarder and the importance of relying on industry professionals to avoid the pitfalls for exporting
- DOC representatives joining us for conferences and informing our members of their services and initiatives;
- NCBFAA’s weekly e-newsletter continually providing DOC’s Commercial Service with a forum for publicizing its efforts to increase export activity in this country.
Through efforts such as these, and in many other ways, the NCBFAA seeks to engender an understanding and appreciation on the part of the public and private sectors of the critical role this industry plays in the commercial life of America.
At NCBFAA, Leadership believes that member growth, retention and benefits are the first priorities, which is why we sponsor ongoing member-get-a-member programs and encourage members to share their membership experiences with others who have yet to join the Association. By highlighting instances where NCBFAA assistance, advice, information or outreach helped to avoid or overcome business challenges to their enterprises, members do much to expose others to the inherent value of belonging to an organization established to further their interests.
One very important benefit that members enjoy is access to a network of committees that covers all aspects of the transportation logistics industry and that is staffed with smart, creative, and interested people. Each is devoted to achieving success and profitability for their fellow practitioners in the knowledge that it will make the industry stronger financially. This nurturing approach is intended to build a community of participants who not only look out for their interests but also the overall interests of the logistics community. Within the pages of this report you can read about the work of many of these committees and their competent and capable members.
In keeping with its emphasis on the importance of members, the senior management of the Association rests with an unpaid, volunteer Board of Directors and Officers elected by the Regular Members to two year terms. These folks are listed at the front of this Annual Report and include the 2012 Officers: President Darrell Sekin, Jr., Chairman Jeffrey C. Coppersmith, Vice-President Geoffrey C. Powell, Treasurer William S. App, Jr., and Secretary Amy Magnus. The process for rising to the presidency of the Association is unique to each one but as to the current one, I like to think I had some minor input into that. It did not seem that long ago when a colleague of (now) President Sekin was looking for more new volunteers to "step up," that I mentioned his name had appeared on numerous attendance lists for various significant committee meetings where he was creating a reputation as a natural leader in terms of knowledge management of the industry. Little did I know that one day he would become our Association’s President. Just goes to show, if you step up to the plate by raising your hand to become involved – you just never know where it might lead!
Of course, our volunteers cannot do it alone; they rely on the support of our dynamic NCBFAA Team, whose department heads have accumulated more than 75 years’ combined experience with the NCBFAA since its relocation to Washington, DC, where I am joined by Kim O'Beirne, Conference & Meeting Coordinator; Jeff Short, Membership Director; Tom Mathers, Communications Director; Kimberly Murphy, Accounting Director; Drenda Williams, Project Assistant to EVP and Member Services; Cecilia Ferrara, NEI Education Coordinator; Porter Watkins, Assistant Administrative / Project Coordinator; Federico "Kiko" Zuniga, NEI Director; David H. Tran, NEI Project Coordinator; Cathy Kouko, NEI Admin Assistant; and our newest addition to the Team, Chrystal Hunter, Administrative Assistant/Reception Coordinator. We work not only to carry out the policies of the governing Board, but also to assist in providing our members with tools necessary to grow and prosper, while encouraging communication, collaboration and advocacy within the industry.
Thanks again for your support!
|NCBFAA Treasurer’s Report
By William S. App, Jr.
During this first year of my term as NCBFAA Treasurer, it has been an honor and privilege to serve the membership of this great organization with which I have long been associated. Throughout my affiliation with the NCBFAA I have always encouraged my industry colleagues who had not yet joined to step up and be part of an organization whose only mission has always been the improvement and growth of our industry. But undertaking that mission requires not only belief on the part of those who support the mission but also the resources supplied by their dues and other financial contributions.
In my role as Treasurer, I am responsible for ensuring that the Association exercises its fiduciary responsibility in the expenditure of the resources entrusted to it in such a way as to not jeopardize the organization’s fiscal strength and financial stability. This is accomplished through rigorous oversight and prudent management of all Association expenditures incurred throughout the year. The results of this judicious application of fiscal management are apparent in the financial statement at the conclusion of this Annual Report.
As you will see, the financial situation for your Association is sound and we attribute that to several factors. Income has been healthy with revenue exceeding budgeted numbers for our Conference and NEI which more than offset a softening of inflows from dues owing to consolidations and less than stellar economic conditions. On the expense side, all of our components have worked diligently to be as careful as possible in expending funds and it has paid off as they have generally closed out the year at or under budget. In addition, our Audit Committee utilizes a detailed report to review the Headquarters office procedures for monitoring purposes.
Of course, I would be remiss if I didn’t acknowledge the fine work done by our office management and accounting staff in their day-to-day oversight of the budget. Part of this effort involves working to consistently reduce redundancies related to time spent performing the Association’s business as well as in carrying out the policy of the Board of Directors.
In the last report, my predecessor included the below statement, which I think is still very appropriate for 2013:
The Budget Committee will:
- Closely scrutinize all expense accounts
- Monitor more closely all spending against the budget and report any discrepancies
- Continue to make suggestions on how to improve the finances to the Board through the Executive Committee
- Work with all parties to explore ways of spending our limited funds to the best benefit of the association.
The Board of Directors should:
- Support the work of the Association and its committees by actively working with the committees and encouraging firms to attend the seminars and conferences of the Association
- Actively solicit new members and sponsors for the Annual Conferences
- Actively support and encourage a positive PR effort on behalf of the Association
- Listen carefully to financial suggestions and act in the best interest of all members
Our Washington staff should:
- Carefully monitor expenditures, making sure that expenditures are properly approved and coded to the proper account
- Monitor administrative expenses and make suggestions for possible savings in these expenditures
- Pursue possible alternative sources such as grant money and reductions in expenses such as the use of interns.
NCBFAA Customs Committee Report
By Mary Jo Muoio, LCB, CCS
Thank you for the opportunity to serve as Chairwoman of the NCBFAA Customs Committee.
If the NCBFAA counted terms of the Customs Committee, and indeed if there even was a Customs Committee from day one of the NCBFAA, then May 2012 would have been the start of its 58th term. The membership of the NCBFAA has benefited from the service of the countless volunteer members who have served on this and other committees and off spring subCommittees, working groups, task forces and the like. Currently the area representatives to the Customs Committee are:
- Area 1 Leman (Chip) Bown
- Area 2 Mary Jo Muoio
- Area 3 Kenneth Bargteil
- Area 4 Myra Reynolds
- Area 5 Scott Larson
- Area 6 Gary Ryan
- Area 7 David Meyer
- Area 8 F.C. (Pancho) Averill
- Area 9 Daniel Meylor
Presidents and past Committee Chairs and Co-Chairs. We are also expertly represented and counseled by NCBFAA Customs Committee Counsel Alan Klestadt and NCBFAA Legislative Representative Jon Kent.
The issues addressed by the Customs Committee are as varied as our businesses. Subcommittees or working groups have been established for the more enduring issues; these groups come and go as issues warrant and participation is open to any NCBFAA Regular member. Currently there are groups established to focus on the Importer Security Filing chaired by Tom Malloy, Remote Location Filing chaired by John Peterson, Broker Regulations and Role of the Broker chaired by Ken Bargteil, Trade Interruption and Resumption Planning chaired by Mary Ann Comstock, Centers of Excellence and Expertise chaired by Mark Shacklette, Automation chaired by Fred Klemashevich, and ADD/CVD subcommittee chaired by Myra Reynolds.
The Customs Committee works closely with other NCBFAA committees and groups including the Regulatory Agencies Committee (RAC), Drawback Committee, Carriers Best Practices Committee, Large Broker & Forwarder Committee, Affiliated Presidents Network, and the Transportation Committee.
The Customs Committee meets monthly on teleconferences organized by Committee Vice-Chairman Daniel Meylor as well as in person several times a year and also holds full-day meetings with CBP several times a year. Many, many single-subject meetings are held throughout the year both as internal meetings and with CBP as issues warrant. The subcommittees meet on individual schedules.
The Customs Committee and supporting groups attempt to focus our resources on issues with the greatest impact on the NCBFAA membership. Local issues are usually addressed by the Area or APN Representative from that locale. The Customs Committee monitors local issues to watch for trends or situations which should be addressed nationally. While never making the official Committee agenda, there are countless questions answered and issues resolved on a weekly basis. Dan Meylor jumps right on these issues and gets the right parties talking to each other to resolve. He is truly an unsung hero for the membership.
There are several significant issues which have remained on the Committee agenda over the last year with automation and broker regulations front and center.
The interests of the NCBFAA membership are the focus of several resources. Amy Magnus continues to serve as the "Face of ACE." In this capacity, Amy is an operational user who can answer member questions and guide them on the path towards successful use of ACE features. In her words, "I try to be a point of contact with our members who may have concerns or need answers. I keep a close relationship with the parties at CBP who can answer most of our questions."
As more and more agencies moved to ITDS, we recognized that we could benefit from closer communication with CBP regarding ITDS plans. Amy Magnus volunteered and this was very well received by CBP.
The NCBFAA Automation Subcommittee chaired by Fred Klemashevich holds monthly conference call meetings with CBP. The calls focus mainly on ACE features, functionality and fixes. The subcommittee authored an ACE tool kit that is available to all Regular Members for free and can be found on the first page of the NCBFAA Website, www.ncbfaa.org. It is a tool that can help new users get started on ACE. Reviews were positive and in the words of one member, "Thanks to the ACE tool kit that was put out and the information that CBP put out, my comfort level has risen and will transmit my first ACE entry tomorrow"
NCBFAA also has an ACE Taskforce chaired by Ken Bargteil, which met in late 2012. As CBP leadership and methodologies for ACE development changed, the taskforce met to evaluate the NCBFAA white paper and determined that the priorities established by the NCBFAA were still valid. In recognition of the importance of software vendors developing ACE solutions, the NCBFAA took the initiative to offer to host a second ACE Vendor Conference. NCBFAA staff will provide critical support to organize and host this event; CBP will provide presenters and our members will benefit from engaged vendors.
Customs Regulations for Brokers and Role of the Broker
Work begun during the previous Customs Committee term continues. The original task of reviewing Section 111 of the customs regulations expanded to considering other sections of 19CFR which address broker actions and expanded even more to a broader consideration of the role of the broker. At the April 2012 Conference, CBP Deputy Commissioner Winkowski asked the NCBFAA President to tell CBP how we see the 21st century customs broker. This led the Customs Committee convening a small think-tank, which brainstormed on ways we could bring value to both our clients and CBP. CBP has expressed an interest in utilizing the relationship that brokers have with their importer customers to assist with their mission. The NCBFAA developed a concept that would provide a way for CBP to know that the importer is known to the broker. This concept was very well received by CBP management who enthusiastically responded to our initiative. The committee continues to work on developing this concept into a program which will position the broker to bring additional value to the importer.
The Core Committee, a group of NCBFAA members focused on the Section 111 rewrite project, continues to develop proposals for regulatory change, to meet with CBP, and to work for a regulatory framework beneficial to brokers. This Core Committee is ably chaired by Ken Bargteil and is addressing all aspects of Section 111 including professionalism, permitting, broker examination, confidentiality, reporting and recordkeeping, relations with unlicensed persons, powers of attorney, bona fides, CF5102, flier code misuse, and last, but not least, broker penalties.
Customs Committee members are eager to serve the members in their area. Committee meetings are open to NCBFAA Regular Members and subcommittees are wide open for participation. If any NCBFAA member has a concern or issue, which the Association should address, please speak up, please step up.
|NCBFAA Drawback Committee Report
By Michael V. Cerny
In 2012, the Drawback Committee worked towards obtaining some uniformity among the drawback centers, as well as working with CBP to streamline certain cumbersome and outdated drawback processes. Members of our committee are involved in a joint Customs-Trade working group headed by CBP’s Laurie Dempsey. Specific issues addressed include modernizing proof of export requirements, streamlining privilege applications, and addressing liquidation issues. These efforts appear to be bearing some fruit as we have recently seen Customs embrace a shorter and more to-the-point privilege application template. We expect more changes over the next year as we work through issues with Rulings & Regulations that, we hope, will lead to a better overall drawback process.
Many members of our committee are engaged with Customs on a number of fronts, including various committees in the Trade Support Network, concerning the development of ACE. For filers of consumption entries, the transition to ACE is imminent. By contrast, for drawback filers, there is nothing in ACE right now to which drawback filers can transition and any future process is still being developed. We are working closely with Customs to shape how this future process will look, and to find ways to enhance functionality to the benefit of our members, the trade, and Customs. We anticipate working on the ACE development of a truly electronic drawback summary that will be transmitted via ABI in ACE, possibly with the use of document imaging for submission of backup documentation.
Finally, we are continuing to monitor the activities in Congress to reform the drawback process through legislation. Legislation was introduced by the Ways & Means Committee in the House at the end of 2012 as part of the larger Customs Reauthorization bill, but that bill did not move further due to other issues. We are engaged again with both Ways & Means and the Senate Finance Committee over the Reauthorization Bill expected in this Congress and hope to be actively involved in shaping the drawback sections of that bill. As always, we are very thankful to NCBFAA Legislative Counsel Jon Kent for his hard work in ensuring that our voices are heard on Capitol Hill. We will continue to fight for statutory language that is acceptable and beneficial for our membership.
Legislative Representative’s Report
By Jon Kent
Everything you’ve heard about the Congress is true -- it’s very contentious, painfully slow, and has difficulty in moving even the most non-controversial bills to passage. But, having said that, it is OUR Congress and we have to be positioned when it springs to life. In the meantime, many of us who work on Capitol Hill have spent more time with the agencies, such as CBP, TSA, FMC and Food and Drug Administration (FDA), where there is continued urgency to demonstrate how regulation affects the private sector and our portion of the economy.
Nevertheless, let’s take stock of what happened on Capitol Hill in 2012.
First and foremost, NCBFAA had its most successful GAC ever. Our numbers were unprecedented – 159 of us; our costs were down; and the quality of our program under the guidance of Mary Peglow was top-notch. This coming year, Mary will team with new GAC Co-Chairman Jerry Becnel of JW Allen in New Orleans.
On the legislative front, much of the year was spent "teeing" up a Customs Reauthorization bill, which was finally introduced by House Ways and Means Committee leadership at the very end of the year. NCBFAA’s role has been to work behind the scenes with staff – principally the now-retired Russ Ugone – providing a reality check for how the legislative provisions impact customs brokers. While the bill that was introduced has some flaws – which we are attending to this year – this time was well-spent at the GAC and throughout the year. We have now submitted detailed comments to the Congressional committees, principally through the fine analysis provided by Customs Committee Chairwoman Mary Jo Muoio and Vice Chairman Dan Meylor.
On the transportation front, NCBFAA’s most significant accomplishment during the year was amending the huge Congressional transportation bill, thereby excluding customs brokers, ocean forwarders, NVOs, and air cargo agents from the new licensing and bonding requirements that otherwise apply to companies arranging for trucking services. Although there has been persistent disinformation to the contrary, customs brokers who arrange for trucking to facilitate or otherwise participate in the continuous or through movement of international cargo moving via ocean or air are not considered property brokers subject to the statute and will not need to obtain any additional bonds, insurance or make any new registration as might otherwise be required by that law.
Finally, as mentioned, the Association was absorbed in CBP and FDA efforts to modernize their processes. NCBFAA has most particularly been involved in a dialogue with CBP about the "Role of the Broker," meeting with considerable success in educating the agency about the opportunities that exist from employing the talents and experience of a customs broker to assist the agency. FDA, for its part, has worked to emulate this outreach to industry, interacting with the RAC and its Chair, Roger Clarke, on a continuous basis.
NCBFAA PAC Annual Report
By Jon Kent
NCBFAA Political Action Committee (PAC) raised and donated more funds in 2012 than ever before in its history. It is a great achievement that reflects on the hard work of the fundraising committee and the generosity of our members.
Congratulations to you all!
The numbers: the PAC raised $18,815 in revenue and donated $15,500. We supported the campaigns of 15 candidates for Congress, 9 of whom were Republicans and 6 were Democrats. PAC Chairwoman Kathy Murray has set even higher goals for 2013.
The NCBFAA is critically important to the strength of our presence on Capitol Hill. As we always say, the PAC never buys votes, but it ensures the election to Congress of candidates who recognize the importance of international trade and the viability of our businesses. Candidates often have particular links to customs, ocean shipping, air transportation, and homeland security.
Recipients of campaign contributions in 2012 included:
- Members of the House Ways and Means Committee; Reps. Kevin Brady R-TX, Charles Boustany R-LA and Sander Levin D-MI.
- Members of the Senate Finance Committee; Senators Bill Nelson D-FL and Chuck Grassley R-IA.
- Members of the House Judiciary Committee; Reps. Bob Goodlatte R-VA, Lamar Smith R-TX.
- Member of the House Transportation Committee; Tom Petri R-WI.
- Members of House Homeland Security; Peter King R-NY and Henry Cuellar D-TX.
- Member of the House Leadership; Rep. John Larson D - CT.
- Member of House Small Business Committee; Rep. Nydia Velazquez D-NY.
- Chair of the Port Caucus; Rep. Ted Poe R-TX.
- Member of the House Appropriations Committee; Rep. Adam Schiff D-CA.
- Challenger from the Port of LA/Long Beach, Gary DeLong.
The PAC doesn’t succeed without our great volunteers at the Annual Conference and the GAC. Working with PAC Chairwoman Kathy Murray are Mary Peglow, Kathy Carlton, Michelle Frances, Julie Moore, Trisha Green, Leah Ellis, Donna Mullins, Anne-Marie Bush and Lisa Gingerich.
Thank you, thank you, thank you.
|Transportation Committee Report
By Janet Fields
In April, Transportation Committee Chairwoman Janet Fields and Vice Chairwoman Melzie Wilson restructured the committee to define four separate and distinct subcommittees, each with their own chair and members.
Air Freight Subcommittee Chairwoman Donna Mullins
This committee handles all import and export airfreight issues for the NCBFAA. The Chair has established and maintains regular contact with the TSA as well as airlines and others involved in airfreight transportation. Committee membership is comprised of those involved in airfreight issues.
In March, Chairwoman Donna Mullins was invited to attend as a panelist on compliance the 37th Annual FAA Conference in Washington, DC where she provided attendees with critical insights from the industry’s perspective into the role of compliance. In that connection, the subcommittee continues to follow closely the developments of the Air Cargo Advance Screening (ACAS) pilot program.
During the 2012 NCBFAA Annual Conference in Florida, the subcommittee prepared and delivered a well-received, dynamic panel on Air Freight Coalitions – government and industry that included representatives from the forwarding community, airlines, TSA and CBP. In addition, the group worked closely with our membership and TSA to obtain a good understanding of the Security Threat Assessment (STA) renewals and the use of AR’s.
In addition, we supported other industry associations in the "Upstream Screening" proposal and, in conjunction with the Airforwarders Association, supported and won an exemption from regulations under the FMCSA (Sec 14916)
**Members: please remember to submit your NDAs**
NVOCC Subcommittee: Chairman Rich Roche
This committee will address all issues involving NVOCCs and will maintain regular contact with the FMC and transportation counsel.
Committee members are chosen according to interest in the NVOCC issues.
Export Compliance Subcommittee: Chairwoman Paulette Kolba
This committee will address export compliance issues with government agencies, including but not limited to, U.S. Census Bureau (Census), CBP, Bureau of Industry and Security (BIS), State Department and Office of Foreign Assets Control (OFAC).
Committee members have export compliance responsibilities within their organizations and represent small, medium and large forwarders. The committee is limited to one individual per member company, although other staff members from those companies are welcome to join in monthly conference calls.
Logistics Subcommittee: Chairwoman Melzie Wilson
This committee will concentrate on the movement of freight via all modes other than air and NVOCC issues, including but not limited to, ocean, rail and truck. Regardless of whether the cargo is imported or exported, this committee will cover inland freight issues as well as demurrage and detention challenges at the ports in addition to carriage of freight via ocean. Chairwoman Wilson also co-chairs the Carriers Best Practices Committee and will serve as the liaison with these committees.
In May, President Darrell Sekin, Chairwoman Janet Fields and Transportation Counsel Ed Greenberg met with FMC Chairman Richard A. Lidinsky to discuss current issues while confirming our commitment to work with the FMC to protect the public from unfair shipping practices.
Vice President Geoffrey Powell and area representatives on the Transportation Committee have held several meetings with CBP and Census to liaise between the two agencies regarding the delayed census regulations.
For the first time ever the Transportation Committee was approached by BIS to provide a couple of speakers at their outreach program in Washington, DC. The speakers representing the NCBFAA, Paulette Kolba and Pat Fosberry, received high compliments from BIS as well as the conference attendees.
In addition to working with security and export compliance agencies, the Export Compliance Subcommittee is developing a repository of forms and information for our members use.
Following the September GAC, Transportation Committee members met with CPB Executive Director of Cargo and Conveyance, Security Dan Baldwin; FMC Deputy Director, Office of Consumer Affairs and Dispute Resolution Services (CADRS) Jennifer M. Gartlan; and Assistant Director Cargo Facilitation, Security & Standards Michael R. White.
The implementation of M1 ACE release on September 29, 2012, brought a new set of challenges for our members and our participation in weekly meetings kept our members informed on the best way to conquer those challenges.
Our committee members kept abreast of the West Coast Strike situation and subsequent East Coast Labor situation. We continued to keep members informed as soon as developments occurred.
Our goals for the upcoming year include developing a repository available on the NCBFAA website where members may obtain information and assistance on our industry, not readily available elsewhere.
|Regulatory Agencies Committee Report
By Roger Clarke
The RAC continues representing the NCBFAA membership with federal agencies other than CBP. The RAC is not a principal standing committee but its structure remains as one with a representative from each of the nine NCBFAA Areas with additional representation from the Pacific Coast Council and the Northern Border Brokers Associations. The committee continued with monthly conference calls along with an extended face-to-face meeting at this year’s GAC. The committee has been very fortunate to have multiple representatives from the FDA attending most of our conference calls. The committee continues liaison with other Participating Government Agencies (PGA) requesting their participation when appropriate.
Industry Working Group
In January 2012, the Express Association of America, an association comprised of four major express courier companies, organized a coalition of stakeholders dealing with imports regulated by FDA. The coalition is comprised of various trade associations, importers, individual brokers, and other related service providers and was named the Industry Working Group (IWG). The IWG reviewed various FDA operations, established benchmark goals with FDA, addressed stakeholder’s areas of concern, and helped FDA establish a more efficient and uniform process in protecting public health and safety. Various subcommittees were formed including operations, communications, informational technologies, and training.
The RAC took a leadership role in addressing FDA operational issues. The RAC made recommendations during a number of conference calls and furnished written comments for IWG review. The IWG compiled reports from the various committees and developed written comments addressed to top FDA management. In May 2012, the IWG sent 17 recommendations on practical steps FDA could quickly take to facilitate cross-border trade. Many of the issues addressed corresponded to independent work being done by the RAC such as:
- Consistent release and policies throughout all ports.
- Improved communication to industry on various commodity requirements and FDA sampling status.
- Improved outreach to the trade including two way communications for a better understanding of real world supply chain processes.
- IT training including PREDICT, ITACS, and MARCS.
- FDA trusted partner program.
- Reduction of FDA hold times.
- Centralized FDA document review process including extended review processing times.
On October 10, 2012, FDA sent the IWG a written response to the 17 recommendations acknowledging the agency is working on several of the recommendations and would take the balance under consideration.
RAC Binding Ruling Proposal
The committee continued its efforts to establish an FDA Binding Ruling procedure similar to the one offered by CBP. The committee had developed, and sent to FDA a written proposal with suggested procedures. FDA has responded that it is still under consideration but has been delayed due to the implementation of the Food Safety Modernization Act (FSMA). The committee continues to bring this proposal up to FDA requesting implementation as it would offer a higher level of reliability and consistency in data transmissions.
FDA FSMA Implementation
The FSMA requires all facilities to reregister on even numbered years. The FSMA requires foreign facility registrations to designate a U.S. Agent that will now assume new, and possibly extensive, financial liability. Throughout the year, the committee has attempted to address and convey to FDA various concerns related to the U.S. Agent and registration anomalies. The committee has attempted, with limited success, to obtain clarification from FDA on the U.S. Agent removal and acceptance process for FSMA U.S. Agents originally accepted under the Bioterrorism Act. While open for discussion the agency has not furnished the RAC, nor published in the FSMA Q&A, specifics on this process. The committee has furnished various issues to FDA related to the current U.S. Agent acceptance process, which is still under review for future comment.
Filer Review Guidelines and FDA Review Audit
The major RAC project for 2012 was addressing issues with the FDA filer review audit protocols and lack of uniform audit guidelines. Under the FDA Transparency Initiative many of the agency’s legacy procedures and policies came under review. One procedure being reviewed is the current independent FDA District filer review system and the lack of uniform national filer review guidelines. FDA has established an internal workgroup to study and develop a guideline document. The RAC conducted numerous discussions with the FDA Division of Import Operations and Policy trying to address many of our industry issues with the current process. Even after voicing our Association’s concerns and sending written comments questioning FDA’s legal authority, the agency continued posting filer review results on the Internet.
The RAC continues trying to have direct interaction with the filer review workgroup but we have not had success in opening any formal dialog. To advance our efforts for communications, the RAC developed written comments on five major issues our Association feels need to be addressed in any guideline document. On September 27, 2012, a formal NCBFAA letter was sent to Ms. Roberta Wagner, FDA Assistant Commissioner for Field Operations, addressing the following issues that must be addressed before publishing the formal protocol:
- Entity identifier code (MID).
- NCBFAA binding ruling proposal.
- FDA product codes.
- Remote location filing of FDA regulated merchandise.
- Clear standard for review enforcement with a due process structure.
The letter also requested the NCBFAA be included in the guideline development and have an opportunity to review any proposal prior to implementation. No formal FDA response has been received to our letter but the RAC continues to bring up these issues during our phone conference calls.
FDA MARCS Import Trade Auxiliary Communication System (ITACS) Implementation
In March 2012, FDA started national implementation of its web based ITACS system. Several of the RAC members were participants in the ITACS beta testing in the FDA Los Angeles District. The committee continued working with FDA pointing out program issues and successes. The initial nationwide implementation was completed in December 2012 and the RAC continues to work with FDA in the development of future ITACS enhancements. Recognizing the NCBFAA efforts for a smooth ITACS implementation, the FDA Import IT Division has approached the RAC to continue working with them in the development of a secure Account Based Management System for completed electronic transfer of FDA documentation. The committee will continue to work with FDA in the development of future ITACS systems.
Expanded RAC Outreach to Various PGAs
To enhance the effectiveness of the RAC with PGAs, three subcommittees have been formed to open communications with USDA, Consumer Product Safety Commission, and Fish & Wildlife Service. The committee is presenting several issues to USDA relating to airport and border release time frames and requesting they participate in the committee phone conference calls. The three subcommittees will solicit input from the membership on any issues relating to their respective PGA. The full committee will continue to monitor the FSMA implementation and try to address any regulatory issues which could affect our membership.
|NCBFAA Educational Institute Chairman’s Report
By Kenneth Bargteil
The NEI is dedicated to advancing the education of global trade professionals while setting the gold standard for continuing education in the international trade industry.
The NEI underwent extensive change in 2012 with a new Chairman and a new vision that quickly brought a new order of business into focus. The Chairman called for greater participation, and with more than 50 new volunteers, he reconstituted the NEI into seven functional units. These new subcommittees were tasked with creating those elements needed to construct a distance learning institution and realize the mission of becoming a fully accredited college for supply chain management and global logistics. The subcommittees comprising this new structure are:
- the Steering Subcommittee, with its Chairman Bob Perkins charting the course toward accreditation,
- the Content Subcommittee directed by Chairwoman Kristi App developing standards, style and organization for the courses and library from which the Educational Institute deliverables will be made available,
- the IT/Administration Subcommittee guided by Chairman Steve Powell delivering the automated system to house our content and administer a distance learning program,
- the CES Subcommittee led by Chairwoman Jan Fields reassessing the requirements of trade professionals and tailoring that program to better meet those needs,
- the CCS Subcommittee and its newly installed Chairwoman Karen Damon refreshing and enhancing that program while creating a second tier of certification for masters of customs compliance (MCS),
- the Marketing Subcommittee headed by the NEI Executive Director Kiko Zuniga rebranding the NEI to better align with its expanded target and reaching out through social media and dissemination tools, and
- the Policy Subcommittee conducted by the NEI Chairman, re-examining all existing policies; putting everything on the table for the purpose of better responding to member and market expectations and opportunities.
With the new subcommittee structure in place specific tasks were identified as mission critical and Work Groups were organized to undertake those efforts. In the CCS Subcommittee, Brian Barber, our former NEI Director accepted to chair the MCS Work Group. Likewise Shannon Whitt took on responsibility for the Content Review Work Group, Elizabeth Maxwell chairs the Test Questions Work Group, and Karen Damon the Case Studies Work Group. In the CES Subcommittee, Paulette Kolba chairs the Case Studies Work Group and the NEI remains committed to providing ongoing opportunities to accrue all necessary continuing education points on line and free of charge, to include in 2013 free webinars in addition to the case studies.
CCS Subcommittee and Case Study Work Group Chairwoman Karen Damon intends, "To support the original CCS commitment of having a continuing education program that does not place an ongoing financial burden on the participant," and her work group will deliver free online case studies to provide for that. The CCS Case Study Work Group is comprised of Robert Brown, Karen Damon, Donna Clemmensen, Lisa Maxwell, John McKeown, Shannon Witt, and Henry Yeh, who collectively have, "accepted the challenge of building a library of Certified Customs Specialist case studies for 2013 aligning with the guidelines developed by the Content Subcommittee."
Structured guidelines and specified question and answer formats will contribute to the goals set by the NEI in enhancing its reputation for advancing education in the trade. In addition to the authors being recognized for their volunteer efforts in writing a CCS online quiz and the benefit of educating those who participate and elect to take the quiz, the authors will also earn Certified Education Points.
MCS Work Group Chairman Brian Barber wants our members to know that his group is gaining, "traction in reviewing our current content and building the framework for advanced certification programs. We have expanded our workgroup to include members of other NEI subcommittees including the Policy, Steering and Content groups as well as NEI Staff to solicit input for a well-rounded curriculum. This is being done in alignment with our mission statement of continuing education for the trade community and core goal of achieving accreditation within a five-year window. While the Certified Customs Specialist (CCS) Program certainly lays the groundwork for individuals entering our trade, there is a market for advanced certifications delivering in-depth content providing participants the knowledge to be recognized as industry leaders. The target audience for these programs will be those seeking a platform for career advancement or individuals looking to achieve a higher level of understanding in a specific area of focus. Specialties in topics such as valuation, drawback, classification, reconciliation, as well as critical thinking and application in real world situations are all being considered. The road ahead of us is long and winding and the territory uncharted, however with focus, determination and the hard work of our members, the program will take shape and content will be delivered. Stay tuned!"
CCS Course Content Work Group Chairwoman Shannon Whitt advises that, "The purpose of this work group is to review and update CCS course material so that the NEI can administer the CCS Course directly. Each module of the course material is being reviewed by volunteers for accuracy, substance, sufficiency, difficulty and delivery. The review process is clearly an on-going task as regulations and procedures change and the course materials must be updated as new regulations require. This group works closely with the CCS Case Study Group and the CCS Test Questions Work Group to correlate the course material with the case studies and exams. The test questions must eventually be indexed to the CCS course material so that any questions linked to the course material can quickly be identified should that section of course material change. In 2013, this group will complete a final review and update of the CCS course material which is currently targeted to desk level operations in the customs brokerage and international transportation industry with an average of 1-3 years of experience. Once the material has been tested for the CCS course, it will provide a foundation for the advanced CCS certifications."
CCS Test Question Work Group Chairwoman Lisa Maxwell reports that her members are, "working with the CCS Content Work Group to complete the evaluation of the course material and test questions for Part 1 of the CCS Course and will proceed through to Part 4. These groups are working closely with the Content Subcommittee to establish a process and timelines for completion of the project up to and beyond download into the chosen platform." Those Work Groups collaborate closely in perfecting a system that will enable a link of test and quiz questions to course content to control and evaluate any changes that have been, or need to be, made in those materials. The groups are also in contact with the IT/Administration Subcommittee and have offered input into the search for the software platform which will be utilized by the NEI.
The CES Subcommittee Chairwoman Jan Fields reports that, "2012 was (also) a year of re-structuring for the CES committee. We’ve added new faces … and have developed several focus areas to complement our on-line CES Course. In the past, our grandfathering process has taken place at physical locations throughout the country creating challenges with the minimum number of students required to hold a class. We are tasked to develop an on-line grandfathering course for those who qualify. Look for this to be announced in 2013. The on-line CES program has become the backbone of training for experts in the export and international freight forwarding industry. We’ve identified a need for a 101 type training system for those individuals new to our industry or folks who need a 30,000 foot view of the functions and responsibilities of an export administrator. Our committee members have been assigned to develop such a course." Additionally, the modules of the CES on-line course have been segregated and are being offered as stand-alone subject matter to allow students to focus on specific areas of the course, while accruing credits that might be pooled together at a later date for CES certification. Under development in this framework is an export compliance course.
As outlined above, it is our intention to build on the success of our two existing programs. The CCS program will continue offering two paths for participation: the CCS course and a grandfathering option for licensed customs brokers. The course remains a six-month online study comprised of four modules with quizzes and a proctored final exam, also delivered online. The material covers various customs topics and is meant to broaden an imports desk level student’s knowledge base. It is ideal for individuals who have at least one year of experience dealing with imports, who would like to enhance their skills and advance their careers.
he NEI will continue with its current CES program, while it develops an online grandfathering option. The course is delivered online with open enrollment and applicants have up to one year to complete it. It is a deep dive comprehensive course of study comprised of 107 modules, with topics ranging from Export Basics to Cargo Insurance Certificates. It is being offered at a discounted rate for those that have grandfathered into the program and would like to brush up on, or update, their knowledge.
In addition to the legacy deliverables, the NEI anticipates expanding its educational auspices. In 2013, the NEI began publishing a quarterly program that outlines all of the educational opportunities approved for CCS and CES credit. While the program continues to feature those webinars presented by the NEI, it also includes a wide variety of events submitted to the NEI by third parties for evaluation and award of continuing education points. All registration information, including pricing, is available on the NEI webpage.
With rededication to the immediate goal of providing quality training and educational opportunities for global logistics professionals, as clearly indicated above, our long-term goal is to become an accredited institution. Within five years, under the direction of the Chairman and with the hard work of the Subcommittees, Workgroups, the NEI Executive Director, Coordinator and staff, volunteers and participants, we hope to become a degree conferring institution of higher learning. Please join us on our journey, whether it is through volunteering your time and expertise, or by taking one of our courses or webinars, step up to the NEI.
For more information on any of our programs, or if you would like to volunteer, please contact NEI Coordinator Cecilia Ferrara at firstname.lastname@example.org.
|Affiliated Presidents Network (APN) Report
By Scott Larson
The Affiliated Presidents Network (APN) meets monthly via teleconference to discuss a variety of port and association management issues as well as to provide support for NCBFAA committees. The APN also hosts formal meetings in conjunction with the NCBFAA’s two major functions, the Annual Conference in the spring and the GAC each fall.
The APN currently includes 28 local broker and forwarder associations.
- Atlanta International Forwarders and Brokers Association
- Baltimore Custom Broker & Forwarders Association
- Boston Custom Brokers & Freight Forwarders Association
- Brownsville Licensed Customs Brokers Association
- Chicago Customs Brokers and Forwarders Association
- Colorado Customs Brokers Association
- Columbia River Customs Brokers and Forwarders Association
- Customs Brokers & Forwarders Association of Northern California
- Customs Brokers & Freight Forwarders Association of Charleston, S.C. Inc.
- Customs Brokers/International Freight Forwarders Association of Virginia
- Detroit Customs Brokers & Forwarders Association
- Florida Customs Brokers & Forwarders Association, Inc.
- Houston Customhouse Brokers & Freight Forwarders Association
- Independent Freight Forwarders and Customs Brokers Association of Savannah
- International Freight Forwarders & Custom Brokers Association of New Orleans
- International Freight Forwarders/Customs Brokers Association of Charlotte
- JFK Airport Customs Brokers and Forwarders Association
- Laredo Licensed U.S. Customs Brokers Association, Inc.
- Los Angeles Custom Brokers & Freight Forwarders Association
- New York/New Jersey Foreign Freight Forwarders & Brokers Association, Inc.
- Nogales U.S. Customs Brokers Association, Inc.
- North Texas Customs Brokers and Freight Forwarders Association
- Northern Border Customs Brokers Association, Inc.
- Philadelphia Customs Brokers Association
- San Diego Customs Brokers Association
- Washington Customs Brokers and Freight Forwarders Association
- West Texas/New Mexico Customs Brokers Association
A vital resource to the various NCBFAA committees, the APN’s mission is to ". . . facilitate the sharing of information, communication and common issues among local associations and the NCBFAA."
If you’re a member of your local association we appreciate the support. If your local offices are not members of the local APN association, please consider supporting their efforts and join. In addition to members, we are always looking for good active volunteers!
During 2012 we formed a major subcommittee to compile and assemble Standard Operating Procedures (SOPs), to include such things as human resources, governance, membership, law, marketing organizational / flow charts, annual reports, record retention, job descriptions, code of conduct, meeting minutes, anti-trust policies, succession planning, etc. These SOPs will aid current and future APN leaders in the development and business activities within their local associations. All the information will be posted within a secure APN resource on the NCBFAA web site for the exclusive use of our Affiliated Presidents, Secretariats and/or their designees.
Fully 26 of these 28 APN members have included an Association profile in the NCBFAA Annual Membership Directory providing details on their local activities. I encourage you to have a look at this section to become more familiar with all the hard work that takes place at the local level.
Mid-year we were fortunate to add a co-Chairwoman to the APN Committee, NCBFAA Area 3 Director, Michelle Francis, who now assists with the leadership of the APN committee on a regular basis.
In conjunction with the NCBFAA GAC, the APN held an association management retreat. We spent an entire Saturday afternoon discussing various management concerns and association leadership restraints. This was a great opportunity for dialogue among the associations to assist one another and to provide answers to their questions. We plan to host more management retreats in the future.
We thank all the members for their continued support of local associations.
Nominating Committee Report
By Scott LarsonOur slate of officers was inducted into office during the April 2012 annual meeting.
- President Darrell Sekin
- Vice President Geoffrey Powell
- Treasurer William App
- Secretary Amy Magnus
- Chairman Jeffrey Coppersmith
The committee will reconvene this fall to start discussing future NCBFAA leadership to develop and put forth a list of candidates for the 2014 election. If you know of someone who would make a great candidate for possible consideration as future NCBFAA leadership, be sure to pass along the name to one of these committee members:
- Chairman Scott Larson, MOL Logistics (USA) Inc., email@example.com
- Co-Chairman Peter Powell, C.H. Powell Company, firstname.lastname@example.org
- Area 1 Jake Holzscheiter, A. N. Deringer, Inc., email@example.com
- Area 2 Matthew Brauner, Brauner International Corp., firstname.lastname@example.org
- Area 4 Lee Hardeman, Lee Hardeman Customs Broker, Inc., email@example.com
- Area 6 Jack Hubbard, TLR - Total Logistics Resource, Inc., firstname.lastname@example.org
- Area 7 Kathy Murray, CEVA International Inc., email@example.com
- Area 8 Rodolfo Delgado, Rodel International. M.D.H. Laboratories, Inc., firstname.lastname@example.org
- Area 9 Maurine Cecil, Western Overseas Corporation, email@example.com
|Membership Committee Report
By Bruce Goodwin
Membership is the key to any organization’s success – financial, educational and political. Recognizing this, there are certain steps that an organization can take to increase member numbers and increase member involvement. The NCBFAA’s leadership can be highly enthusiastic about the programs and services that are offered to its members, current and most importantly, future. Membership marketing must work hand in hand with all other aspects of our Association in order for membership to continue growing. In the current economy, this is no small task with companies unfortunately going out of business, an increase in companies merging with other companies and companies watching closely how they spend their dollars, with association membership not being tops on their list.
What does the NCBFAA have to offer future members so that they feel their membership dollars were well spent? We have the Monday Morning eBriefing, the Annual Membership Directory, the Annual Conference, the GAC and we have the dedicated professionals who make up the Association to pass the "good word" on. Politically, we have our Washington representatives making sure that the NCBFAA’s opinion is heard throughout Congress and that when legislation pertinent to our industry is coming up for discussion and a possible vote, that in the backs of a Senator’s or Representative’s mind is "maybe we should get the NCBFAA’s input on this" before they go forward. That is a truly valuable asset that benefits not only our members but also our industry.
I did not mention our latest and most aggressive program, the NEI with its CCS and CES programs. How can this not be attractive to every logistics company in the U. S. with the talk of continuing education in our industry being a current hot topic, especially with CBP?
With all of the above being said, it is still up to all of us as Association members to sell the NCBFAA to any and all companies that are not yet members. We have instituted the Member-Get-A- Member campaign where members will be eligible for prizes up to a $1,000 gift card. So, thank you all for supporting our Association and continuing to see the membership grow.
I would like to thank barbara reilly and the Washington staff, especially Jeff Short, for their continuing effort in helping grow and retain our membership numbers. Thank you to the members that brought in new members and ask them to never stop praising the glories of our Association. And to borrow Billy App’s quote from years ago "stay involved if you already are and get involved if you’re not!"
Large Broker & Forwarder Report
By Leman G. (Chip) Bown, Jr
The Large Broker & Forwarder Committee (LB&F) focuses on the impact of directives, actions and initiatives by CBP, FMC and other government agencies, on large member corporations. As a subcommittee of the Customs Committee, LB&F is charged with the identification of issues, developing proposed solutions, and escalation to the Customs Committee.
In 2012, the LB&F Subcommittee conducted six bi-monthly conference calls. Major areas of focus were continual updates on the progress of ACE and the Portal; discussions on the 111 Rewrite project; CBP’s Simplified Entry pilot; and Centers of Excellence and Expertise/Account Management (CEEs). One example of an LB&F initiative was the recommendation that a Customs Committee work group be formed to provide feedback to CBP on how the CEEs work with brokers. Calls between this work group and CBP generally occur every two weeks. The group is still formulating CEE process interaction with CBP and adopting solutions that work for all parties.