**V2:** **Jan 7, 2005**

1.  **Account Management**

    a.  November 30, December 1: Create/Maintain Broker Accounts

        i.  **Trade Participants**: Bob Perkins (UPS), Stuart Schmidt
            (Menlo), Michael Ford (BDP)

    b.  December 2: Broker Management

        i.  **Trade Participants**: Stuart Schmidt (Menlo), Michael Ford
            (BDP)

    c.  November 30, December 1 & 2: Create/Maintain Carrier Accounts

        i.  **Trade Participants**: Verna Schultz (Railinc), Orrin
            Ramstad (Northwest), Ron Robertson (Con-Way), Robin Reynolds
            (UPS), Steve McQueary (Brown Lines)

2.  **Post Release**

    a.  November 30: Validate Entry Summary - Entry Summary Matching

        i.  **Trade Participants**: Tom Anastasi (Fed Ex), Melissa Irmen
            (Integration Point), Art Litman (Fed Ex), Sally Meier (IBM),
            Barry Obrien (Hasbro)

    b.  December 1: Validate Entry Summary - Entry Types

        i.  **Trade Participants:** Tom Anastasi (Fed Ex), Melissa Irmen
            (Integration Point), Art Litman (Fed Ex), Sally Meier (IBM),
            Barry Obrien (Hasbro)

    c.  December 2: Validate Entry Summary - Entry Types

        i.  **Trade Participants:** Tom Anastasi (Fed Ex), Melissa Irmen
            (Integration Point), Art Litman (Fed Ex), Sally Meier (IBM),
            Barry Obrien (Hasbro)

#####  

##### ACCOUNT MANAGEMENT

##### 

##### [Create/Maintain Broker Account and Broker Management - November 30 -- December 2]{.underline}

[Action items for the Trade]{.underline}

1.  Check with Accounts Committee and Broker Account Subcommittee on
    whether changing the old permit number would impact anyone. What is
    it used for?

2.  Need to vet new Account structure proposal through the Broker
    Account Subcommittee. Do we want to add the district as a level and
    do we differentiate between the permit ports and the RLF ports for
    clearance?

3.  What about impact on trade if you maintain the corporate structure
    at the filer code level? ACCESS ISSUE. Having the names is not an
    issue but beyond that is. Need to restrict access to corporate
    information at the filer code level. Whenever home addresses and SSN
    numbers are involved, then we need some way to restrict access.

4.  Reports Requirements -- Need conference call to discuss bulk data
    download requirements and why someone would run a report with more
    than 65,000 lines?

5.  What reports do the trade need?

The following paper processes will be automated in ACE:

1.  [Broker Exam Process]{.underline}

    a.  Ability to register and submit on line application

    b.  Ability to pay exam fee electronically

    c.  Ability to print web receipt or email receipt

    d.  Automated withdrawal notification

    e.  Add email address to application

    f.  Electronic notifications

2.  [Broker License Process]{.underline}

    a.  Ability to file application electronically

    b.  How do we capture the articles of incorporation and the evidence
        of partnership electronically?

    c.  Ability to pay license and fingerprint fee electronically

    d.  Ability to print web receipt or email receipt

    e.  Electronic notifications

3.  [Filer Code Assignment]{.underline}

    a.  Ability to file application electronically

    b.  System assigned code

    c.  Electronic notifications

4.  [Broker Permit]{.underline}

    a.  Ability to file application electronically

    b.  How do we capture copies of the state business license, the
        lease or rental agreement, etc?

    c.  Ability to pay fees electronically in one payment

    d.  Ability to print web receipt or email receipt

    e.  Electronic notifications

    f.  Track waiver process

    g.  Standardization of permit number

    h.  What is the impact to the trade if old permit numbers were
        changed?

    i.  National permit -- create on line application

    j.  Should there be a waiver for the National permit?

5.  [Building the Broker Account]{.underline}

Example of New Broker Account Structure

+-----------------------------------------------------------------------+
| \+ Company Account Information                                        |
|                                                                       |
| \+ Filer Code (Corp. License Data)                                    |
|                                                                       |
| \+ Local Permits                                                      |
|                                                                       |
| \+ District (Point of Contact initially the permit qualifier)         |
|                                                                       |
| \+ Port (POC either pre-populated from permit application or          |
|                                                                       |
| entered by trade)                                                     |
|                                                                       |
| \+ Office/Branch code (POC entered by trade)                          |
|                                                                       |
| \+ Port                                                               |
|                                                                       |
| \+ Office/Branch code                                                 |
|                                                                       |
| +National Permit (POC initially the permit qualifier)                 |
|                                                                       |
| \+ District (POC initially the permit qualifier                       |
|                                                                       |
| \+ Port (POC optional)                                                |
|                                                                       |
| \+ Office/Branch code                                                 |
|                                                                       |
| \+ Port (POC optional)                                                |
|                                                                       |
| \+ Office/Branch code                                                 |
+-----------------------------------------------------------------------+

# CBP Account Manager assignment could be at the Company level or the District level

6.  [Triennial Fee]{.underline}

    a.  Send electronic reminder notifications

    b.  Ability to pay fees electronically in one payment

    c.  Ability to print web receipt or email receipt

    d.  Need official form for triennial reporting and certifying you
        meet the requirements.

    e.  New question: Have you been arrested or convicted of a felony
        within the last three years? If yes, provide an explanation.

    f.  CBP is also looking into a continuing education requirement.

    g.  CBP proposal for escalating fees for reinstatement

7.  [Employee List Maintenance]{.underline}

    a.  Is the list of 'all employees' or just those engaged in Customs
        business?

    b.  If the list of employees is maintained in the portal, has the
        requirement to provide the list been met?

    c.  Maintain one contact list for the account with various
        associations.

    d.  Add port to list of master data elements and potentially
        employee start and end date

    e.  Notification to CBP if change in qualifying license or corporate
        officers

    f.  Optional field to indicate employee is authorized to sign
        documents

    g.  Access concern to corporate information whenever home addresses
        or SSN is involved.

8.  [Reports]{.underline}

    a.  Two types account profile reports and transactional reports

    b.  New reporting tool will provide ability to slice and dice data

    c.  Analyze and assess risk

    d.  Prescribe action -- at what level in the account should the
        action plan be stored?

    e.  Track and report -- provide notification on due dates, missed
        dates and completion dates

    f.  Account reports to include list of licensed brokers, license
        qualifiers, permit qualifiers, triennial reports submitted and
        not submitted

9.  [Action Items]{.underline}

    a.  Automation of exam application

    b.  Electronic signature for 3124E

    c.  Revising 3124E

    d.  Electronic fingerprinting

    e.  Standardization of permit number

    f.  Allow waiver for national permit qualifier

    g.  Allow account to view individual Broker triennial reports

    h.  Have you been arrested or convicted of a felony within the last
        three years?

    i.  Continuing education for triennial reporting

    j.  Proposal for escalating fees for reinstatement

    k.  Can the triennial fee and the report be separated?

    l.  Clarification of 19 CFR 111.28 employee list

    m.  If employee list is maintained electronically, does this meet
        the regulation?

    n.  Addition of new data fields, start and end date for employee
        list

####### Create/Maintain Carrier Accounts -- November 30

[1.1.1.x -- Input Account Definition Data for Carriers]{.underline}

1.  Are IRS numbers or Social Security Numbers mandatory data elements?
    Many carriers do not have these. If this is mandatory we are going
    to have problems on the southern border. We may have to find the
    Mexican & Canadian equivalent, if there is one. Does CBP have the
    authority to ask for this?

2.  Canadian carriers have Standard Carrier Alpha Codes (SCAC) codes,
    but can we make other countries do the same? There needs to be some
    unique ID in addition to the ACE ID that identifes the carrier
    account owner. The IRS number and SSN should not be what identifies
    carriers. SCAC or International Air Transport Association (IATA)
    codes could be more appropriate as a requirement but SCAC and IATA
    are not issues by CBP

3.  Can carriers file paper or will everything need to be filed
    electronically? Eventually everything will be electronic via the
    portal or EDI.

4.  How do we handle a business that needs to break down its structure
    into different categories even under one SCAC or IATA?

5.  Carriers participating in FAST will have difficulty using
    independent drivers to cross borders. The independent driver owns
    their own truck, but is hauling goods for another company. Who is
    responsible for filing the manifest? The company that has the
    responsibility for getting the goods from point A to point B is
    responsible for filing the manifest. The driver is responsible for
    his own documents (passport, CDL, etc.) but not for the goods.

6.  For capturing data, which of these transactions is most important to
    us? The driver is probably the most important, because he is the one
    most available...and is responsible for delivering the manifest. The
    company is responsible for preparing the manifest. Whoever produced,
    delivered, or transmitted the electronic manifest is who is
    considered in charge of the vehicle. Penalty is in 1436, and
    references the person driving the truck.

7.  Is there a need for two SCACs, One to identify who is responsible
    for establishing the overall manifest, and one who is the substitute
    carrier \-\-- Need clarification from OR&R.

8.  The carrier files the manifest, what does the air consolidator file?

    a.  Most of the consolidators don't have an IATA code, but they file
        their own house bills. It is the company's IATA code is used.
        The consolidators sometimes have a FIRMS code, or a broker/filer
        code, and sometimes that is used to identify them.

    b.  The policy is to have a standard house air bill, put in the same
        3 letter alpha code, either alpha or numeric house-air bill to
        identify the carrier. To process the transactions, there is
        already a mechanism for how to do it, but for CBP there are not
        the identifiers in place. This may be a policy or regulation
        type level, without this, it is meaningless because we cannot
        enforce anything.

9.  Use of Firms Codes: FIRMs are already maintained by CBP, but for
    expediters they use filer codes which include the entire US. If they
    link direct, they will link the two codes, but if CBP puts it in for
    them, the FIRMs code and filer codes are not linked. FIRMS code
    should be built into the account structure. The FIRMS code only
    applies to a specific location of a manufacturer. House-bills are
    only identified by the name of the owner, not of the company who is
    transmitting it to CBP. In terms of secondary parties how do we know
    in the transaction that there is another party involved? How are
    they authorized?

# Express Consignment Operators

1.  The paperwork filed by Express Consignment Operators the same for
    manifest and entry as other carriers? Everything will look the same
    except for the facility information. UPS has one SCAC (2 -- 4
    digits) code for everything, and an IATA for the planes.

    a.  UPS will give us more information about express consignment.

2.  All of the carriers would like to see Release Information,
    especially what is called mis-deliveries (when something is driven
    off and not 'released'). This wouldn't be in accounts, but would be
    more transactional.

3.  SCACs are 2-4 digits, CBP has always required 4 digits. It would be
    nice if CBP could recognize the 2-3 digit SCACs so that everyone is
    consistent. SCAC & IATAs could be the same for a company. Point of
    contact information should be listed, in some cases an account owner
    & account manager...

[1.1.2.x VALIDATE CARRIER DATA]{.underline}

1.  Validate Postal Address: for U.S. addresses, the process checks that
    it is a valid address by using third-party software. Not sure which
    level of detail is used today, but it is able to identify if a
    physical address actually exists. CBP must determine what level of
    data validation is needed and how many resources are needed to
    support this.

2.  ACTION ITEM: We need procedures on how a new carrier account will be
    created, and how CBP will handle non-managed accounts. There needs
    to be a record on all carriers. A process exists for importers. New
    importers can go to a broker who will have the importer record
    created in CBPs system. The broker will transmit EDI messages for
    the new importer. A process for new carriers does not exist. Brokers
    may not handle carriers. How are carriers going to register to be
    set up as an account? Could we have an on-line application process
    for new carriers?

3.  Miscellaneous Note: Need to target audiences to invite to public
    port meetings. Currently, the ports use whatever type of medium that
    they can find, and usually the attendance is made up of Carriers &
    Brokers. Perhaps having email accounts could make it possible to
    reach more individuals to notify of these public meetings. Maybe if
    we have the SCACs, we could create a membership to have access to
    the addresses or something.

# Validate Postal Address

1.  Does the zip code match the city? Does this street exist? Does the
    actual location exist?

2.  Duplicates: trade would like for the transactions to go through and
    for CBP to correct it later. CBP requests that the person creating
    the record provide their point of contact information, such as a
    phone number, so that CBP can go back to someone to verify the
    information.

    a.  ACTION ITEM: How many small carriers do we currently have?
        (Define what constitutes small.) How do they go across the
        borders now, that is, do they have their own SCAC codes, or are
        they using SCACs of other companies?

# Check for Duplicate Account

1.  For duplicate checks what type of information will be in the system
    to verify the information? Account Name, address, Tax ID no., SCAC,
    IATA. You could have multiple Tax ids for the same address if a
    parent company and its subsidiaries are located at the same address.

2.  Are we getting a download from National Motor Freight? If we do we
    will have everyone's SCAC code per Susan M. So ACE will have some
    information in the system when a new account is being created.

3.  Can a carrier have multiple business categories? Rail carrier can
    also have a truck line that also operates air cargo or sea cargo!!!
    They may all have the same SCAC code. CBP would like to see that
    information when they look at the account. Susan Maskell would like
    to see a picture of the account and know what kind of business roles
    they get involved in?

[1.1.3.x Activate Carrier Account]{.underline}

1.  Account data is set up, you can now process a transaction. The
    system assigns an ACE ID, and then depending upon how the account
    would like to access the data determines how you will follow the
    next steps. For example, using EDI is optional. Another option is to
    set up Portal access. Both EDI & Portal access may be another
    choice. Whether or not CBP will assign an Account Manager is
    determined next.

2.  There currently are no account managers for carriers but it is being
    considered by OFO for the future. E.g. CBP plans to assign one acct
    mgr to UPS per Alice Buchanan but this can change. CBP/OFO is
    working this issue. CBP is planning on one acct mgr per company but
    they may need to expand that in the future, i.e. an acct mgr for
    inbound, outbound, passenger, cargo, or by separate business modes
    handled by the carrier. CBP needs to define what criteria will be
    used to select carriers as managed accounts. CBP needs to define how
    all accounts will get assistance on issues involved with their ACE
    accounts and transactions.

3.  CBP REQUEST: Design the system to accommodate more than one CBP
    account manager. Would like to know which account manager was
    responsible for which level of account activities (e.g. who does the
    imports, who does the air, who does the rail, etc). This may be
    needed if someone at the port would like to talk to the Account
    Manager for a specific division.

[1.1.4.x Carrier Account Approval Notification]{.underline}

1.  There are going to be non-managed accounts who apply for an ACE ID.
    There has to be someone at CBP who takes care of these small
    accounts. his is being worked at in headquarters. There may be an
    Account Servicing desk, someone who sets up this account for the
    carriers.

2.  Need a notification process to inform the account applicant that the
    account was created or that further data is need. What would the
    trade like to see?

    a.  **Trade:** Email with a link, or a PDF attachment. Notify the
        applicant in some way.

    b.  *[Passwords]{.underline}*: trade has dealt with the same issue,
        and they give a temporary password for 24 hours, if it is not
        changed within 24 hours it will be deactivated, and a call must
        be made to get it reactivated.

[1.2.1.x Maintain Account Data]{.underline}

1.  Additional points of contact, address changes, account changes, etc.
    would be included in this. The trade is supposed to maintain their
    account data. The trade would like for CBP to get a system kick-out
    and have to confirm some changes made to the accounts. For example,
    CBP should clean the system of a company goes bankrupt.

2.  For crew information truck carriers are having issues with this. As
    drivers come & go, or one driver works for multiple companies...this
    is always an issue. This will be addressed in the Independent
    Drivers work sessions. In air & sea, the trade provides this
    information to CBP at the point of transaction. This is not really
    an issue, other than with truck.

# 

**[Create/Maintain Carrier Accounts -- December 1]{.underline}**

# Overview of Accounts

1.  ACS is still the system of Record. In Release 5; every business
    entity will be managed in the CBP's newer ACE system. Following
    release 5 new 'accounts' will be created in ACE through methods such
    as EDI and the portal. This new system will be able to recognize
    relationships between the Accounts and recognize if one company has
    two SCACs. These relationships will be recognized after they are
    created. The relationships are not automatic.

2.  AMS (Automated Manifest System): separate data base for carriers,
    brokers, etc. When we bring this over to ACE, is it always going to
    be a one to one coming over as an account, or is there a matching
    process where companies & addresses in each of the systems are
    recognized as one company?

    a.  You will be able to see all of those different entities. Then
        someone from the particular company will have to set up the
        relationships and claim ownership of the different entities.
        When an importer sets up an account, they establish their
        account structure and identify sub-accounts and
        sub-sub-accounts.

# Carrier Bonds

1.  ISSUE: We need to be able to know that carriers have bonds, because
    they're identified one way in one legacy data base, and another way
    for a different purpose in the others. We need to know which bonds
    belong to which carriers. Bonds in ACS are associated with Tax ID#
    not with the SCAC or IATA.

    a.  CONCERN: ACE will be the system of record, and will have SCACs
        in it. CBP will check to see if that SCAC has a bond(s), if the
        system can not make it so that we can see the matches, we will
        need 10,000 people working in the system to put these bonds
        connections in. We can do this for importers, but we need to be
        able to do this for carriers. HOW DO WE RELATE BONDS TO THE
        CARRIER? Carriers want the association of his bonds in his
        master file.

2.  Can ACE set up these relationships and data links with the
    appropriate account? There are over 3 million records in our
    importer file but only 300,000 to 400,000 importers of record so
    there is an overabundance of data and we do not know what records
    are active, accurate, etc.

3.  ***Trade Concern*:** **File cleanup** has to account for seasonal
    things, so doing file cleanups you can't really pass over things
    that haven't been used in a year in 3 months, or 2 years. For
    example, in Rail there are haulage agreements, and no one has soft
    copies. Someone from each company is going to have to come forward
    and list which companies are actually being used.

4.  n Release 2 there was a template loaded that relied on information
    from the trade. In Release 3, everything was imported from ACS on
    the criteria that if this account was inactive for a certain period
    of time, it would not be brought over to ACE. They were brought over
    at the lowest level and filtered so inactive accounts were not in
    the new system. You can not change the information of bond holders,
    so bond validation is put against certain criteria.

5.  For importers, an IR# is listed once, and then the importers of
    record can only be in the system once. For carriers, it appears that
    you may want to have the SCAC listed more than once, and have the
    different divisions or modes broken out separately. For example
    SCAC1 -- AIR, SCAC1 -- RAIL, etc.

6.  If a company has an Tax ID# at the top of the account, can it have
    more Tax ID #s in the lower levels of the account? Yes. There can be
    more than one Tax ID# for an account, so there is not a one to one
    relationship between SCAC and Tax ID#. There is legally only one tax
    id number per company; but there may be many SCACs per tax ID#.

7.  For manifest data, NVOCCs have the ability to transmit information
    to CBP, and air sends information to CBP...we need to look at all of
    the freight-forwarding companies that are automated and
    corresponding electronically with CBP. Are these freight forwarders
    setup as accounts? We will never know of all of the
    freight-forwarders, because there is no regulation that states they
    must be registered.

    a.  Most of the large freight-forwarding companies handle inbound &
        outbound cargo. In Release 7, Export Freight-Forwarders will
        have to be an account because they are heavily involved in all
        of the transaction data for outbound.

# Service Providers

1.  Role of a Service Provider: Acts as a transmitter of data for other
    companies who do not want to do it for themselves. There are service
    providers that are being established to handle the filing of trade
    data for an importer, broker, carrier, etc. In the manifest release
    process, the service provider is just transmitting manifest data for
    other companies. If a company does not want to do EDI or Portal for
    the manifest, hopefully there will be Service Providers to do this
    for those companies.

2.  In 4.x these service providers will be set up as accounts, but they
    will not be associated with anyone unless they are a service bureau,
    and then it will be associated in the EDI profile. CBP would like to
    have information on these groups, such as name, address, point of
    contact, etc. CBP would like to know the service provider, the
    company doing the business, and know of the relationship so no one
    is stealing SCAC codes.

3.  *Trade Request:* Anything with the trade's code (for example 3959)
    that is entered across the border, is sent to the company by the
    Service Provider, and then the Company must contact CBP to resolve
    problems if something was entered that was not their own to ensure
    that nothing is being snuck into the country. The trade would like
    to know if it was a paper entry, or through the EDI, etc....about
    anything that went across the border using their code.

    a.  EX: Conway is using a service bureau. Do we want to know that
        Conway is using a specific service provider? How is that service
        provider associated with Conway and how will ACE know that?

    b.  If a service provider makes an error they are responsible for
        the accuracy of the data.

    c.  Everything thing that happens under Conway's carrier code that
        is filed by the service provider comes back to Conway -- Will
        this also be available in ACE. Will ACE be able to identify the
        relationship between the carrier and its service provider? Per
        Susan, the client rep will have this information.

    d.  If a carrier has portal and EDI access they will still be able
        to access data from the portal that was transmitted via EDI

# Maintain General Data 

1.  This can be done through Portal or EDI, the trade seemed to prefer
    to have this information in EDI.

2.  Each Crew member has their own ACE or FAST ID number. The EDI
    message was made so that the full data for an individual could be
    given, or their ACE ID number.

[Business Specific Data by Mode or Industry (1.2.2.x)]{.underline}

1.  **Airlines** always use IATA codes, and every airline has an IATA.
    Cargo Imp -- an IATA standard message set. It is different than any
    other EDI message. It is a proprietary message. IATA gives CBP a
    dump of all of the IATA codes. There are three main coding systems
    with IATA -- airport, airline, and ICAO (international civil
    aviation organization).

2.  **Rail**: using the UMLER database for the equipment & conveyances
    is the only specific data set for rail. The use of this database is
    still under consideration. Did CBP decide to bring the UMLER
    database into the ACE system? See Action Items. A SCAC can not be
    reused for 5 years after the initial company has dissolved.

3.  **Sea:** Sea also has a SCAC for the company, and the conveyance has
    the Lloyds code and the vessel name, rather than having a
    conventional initial & number. (The Lloyds code is in the MMM
    documentation).

4.  **Truck:** All of the information is in the multi-modal manifest
    data.

5.  **Other:** pseudo-flight numbers, set up to identify that it is a
    code share flight, which means that one company will be the
    owner-operator, and the other company will register with the DOT.

6.  Security -- the Trade Act of 2002 stipulates who can file for each
    mode, and leaves the rail piece open ended. Rail feels slighted over
    this.

**[Create/Maintain Carrier Accounts -- December 2]{.underline}**

# Carrier Report Requirements

1.  The below listed reports were requested by the TSN Multi Modal
    Manifest Committee as part of the TSN user requirement
    recommendation process:

    1.  RT_001 Crossings by Carrier

    2.  RT_002 Crossings by Driver Report

    3.  RT_003 Crossings by Conveyance

    4.  RT_004 Transactions View

    5.  RT_005 Shipment Type Report

    6.  RT_006 Carrier Activity Report

    7.  RT_007 Split Shipment Interval Compliance Report

    8.  RT_008 Preferred Filing Interval Compliance Report

    9.  RT_009 Standard Filing Interval Compliance Report

    10. RT_010 In-Bond Shipment Status Report

    11. RT_011 Unresolved Shipment Control Number Report

    12. RT_013 Unresolved In-Bond Shipment Report

    13. RT_015 Transaction by Party Report

    14. RT_018 BRASS -- Products Report

    15. RT_019 BRASS -- Commodity Code Report

    16. RT_020 Carrier -- Truck -- Driver Report

    17. RT_022 BRASS -- Enry Number Bank status Report

    18. RT_027 In-Bond Types by Port Report

    19. RT_029 Empty Trips Report

    20. RT_030 Release Count Report

    21. RT_031 Time Range Driven Release Count Report

    22. RT_033 Exam Type Count Report

    23. RT_034 Time Range Driven Exam Type Count Report

    24. RT_036 Crossings by Equipment Type

2.  Role of EDI in Release 5

    1.  CBP wanted to reiterate the increased role which EDI should to
        play in Release 5! The future of ACE is to have more information
        EDI driven rather than portal driven. The bulk of the data ACE
        will handle will be EDI driven. We need to start developing EDI
        requirements for EDI users of ACE. However, the portal will
        still be critical for smaller users that will not have EDI
        capability.

    2.  EDI needs to be used for more than transactional
        information/purposes.

        i.  Want to be able to update account data via EDI.

        ii. Want to be able to get reports via EDI

3.  Attendees discussed the TSN Carrier user requirement recommendation
    as contained in MMM --FR-005 summarized below as follows:

    1.  *The carrier account shall include all the codes by which the
        carrier is known, SCAC, IATA, DUNS, IRS, ICAO*

    2.  *Carrier Account will include bond information*

    3.  *Carrier Account shall include all programs in which the carrier
        participates - i.e. FAST, BRASS, etc.*

    4.  *The Carrier account will indicate which parties can obligate
        bonds*

    5.  *Carrier should be able to inquire the history and see who
        obligated their bonds.*

    6.  *Carrier requires capability to view history of all
        transactions*

    7.  *Carrier need to receive Administration Messages*

    8.  *Carrier access all Reference Data -- 19 CFR, HTS and Cross*

    9.  *Carrier require access to "Sanctions List" and "Denied parties
        list"*

    10. *Carrier Access to penalties/liquidation damages*.

    11. *Carrier require ability to electronically send petitions*

    12. *Carrier to receive electrically all notices of penalties,
        decisions* on petitions/mitigations

    13. *Carrier to receive Seizure/Detention notices electronically*

    14. *Carrier to order overtime electronically from all PGAs*

    15. *Carrier to download account data*

    16. *Carrier will have access to compliance rate and "Report Card."
        Type information*

    17. *Carrier requires all monies owed for penalty/liquidated damages
        may be presented on a periodic statement*

    18. *Truck carriers need ACE to track \$5.00 payments.*

    19. *Carriers to pre-register crew members*

    20. *Carriers account will include a listing of all pre-registered
        conveyances with pertinent information*

    21. *Carrier Account to include certificates/licenses issued to the
        carrier by PGAs*

    22. *Carrier to act as Account Administrator for its account*

        i.  *Carrier would like to have more than one Proxy Account
            Owner for their account*

## POST RELEASE

# **Post Release: Validate Entry Summary - Entry Summary Matching -- November 30**

1.  [Entry Summary Matching]{.underline}

    a.  Relationship between entry to summary can be one to many or many
        to one. Examples: IASS, Split shipment, reconciliation.

    b.  Split Shipments

        i.  Split shipments are provided for under §141.57

        ii. For purposes of ACS, for any given entry there is one entry
            date. ACS uses the earliest entry date

        iii. Trade concerns

             1.  How do we handle the entry numbering process for split
                 shipments?

             2.  The trade needs to be able to correlate different
                 arrivals for a split shipment to an entry.

             3.  Sometimes a shipment arrives later than the 10 day
                 regulatory period and the trade must be able to account
                 for this as a new entry

    c.  Entry numbering system

        i.  NOTE: ACS will still be the system of record for any new
            numbering system throughout R5 deployment

        ii. Port code embedded in entry number string today. Trade reps
            stated that this needs to be resolved. Entry may be filed
            with intent to arrive in one port; Needs to be diverted to
            another port.

        iii. Trade reps stated that they need to be able to assign the
             entry number, because CBP is not always open, the system
             may be down, etc., and the trade still needs to create
             entries.

    d.  Need to account for multiple ports per entry summary (IASS,
        recon)

    e.  Need to build in scalability for dates. E.g., An entry may be
        flagged for IASS and the 10 day rule will not apply.

    f.  Matching of data between entry and entry summary

        i.  How will CBP react to differences between the CF 3461 and
            the CF 7501?

        ii. FTZs: Variables due to the manufacturing environment.
            Corrections made on the FTZ weekly entry.

        iii. Country of origin may change between entry and summary.

2.  [Certification at Summary]{.underline}

    a.  Northern border -- Still filing entry and summary separately,
        although certification at summary will increase due to advanced
        filing requirements.

    b.  Do we need to continue the two step process- that is, entry and
        entry summary (3461 and 7501)?

    c.  The two step process is built into the statute (19 USC 1484)

    d.  Although the trade can opt to file the 3461 and 7501 together,
        the two step process cannot be eliminated

    e.  Trade doesn't want to have to duplicate the data sent.

3.  [Entry Summary Acceptance]{.underline}

    a.  The trade has 10 days to file the entry summary from the date of
        release

    b.  The 10 day cut off determines whether the entry summary is filed
        timely; CBP however will continue to accept the entry summary no
        matter when it is submitted by the trade

    c.  Outstanding: What constitutes CBP acceptance of the entry
        summary?

    d.  Two forms of acceptance -- System acceptance and CBP acceptance

4.  [Post entry corrections]{.underline}

    a.  CBP will allow for one transmission of corrections during the 10
        month period

    b.  The one transmission can cover multiple entries

    c.  The correction will result in a liquidation within a two week
        cycle

    d.  No correction results in liquidation within one year

    e.  After liquidation, protest is still possible

    f.  Outstanding: When does the clock start on the 10 months?

        i.  This is dependent on how CBP will define "acceptance"

    g.  Trade concerns: Does this eliminate the use of Supplemental
        Information Letters (SILs) and Post Entry Amendments (PEAs)?

        i.  For legal purposes, under disclosure, the trade has an
            obligation to report discrepancies to CBP. As such, this
            places a burden on the importers/brokers to continue to
            track the SILs and PEAs. Will trade be penalized for waiting
            entire 10 month period to file ALL corrections if they
            become aware of a change earlier in the period?

        ii. The trade, as documented in the TSN Requirement
            Recommendations, wanted the opportunity to leave the door
            open and make corrections as necessary during the 10-month
            period.

    h.  PGA Concerns:

        i.  Who will receive corrections and how?

        ii. What if a PGA has a requirement that a non-conforming import
            be brought to compliance before the 10 month period- how
            does that get reconciled?

5.  [FTZ Process]{.underline}

    a.  Trade requirements to automate the zone admission (214)

    b.  Zone admission process currently targeted for R6

    c.  Do we need traceability between the 214 admission and an entry
        into commerce?

        i.  The 214 admission and the entry will not always match.
            Sometimes there is merchandise that is destroyed or
            exported.

        ii. In today's environment this is monitored via audit

    d.  Trade wants PGA checks done when products are admitted into
        zone, not at summary

    e.  Current line item limit in ACE is a source of difficulty. Need
        an unlimited amount of lines. This applies across the board and
        not just for FTZ weekly entries.

6.  [Warehouse Process]{.underline}

    a.  Trade Concern: the trade would like the ability to identify what
        goes into the warehouse and what goes into consumption

    b.  Need paperless release of warehouse entries

    c.  Proprietors need connectivity -- Automation of communications
        between warehouse proprietor and CBP (ABI, portal link)

    d.  Need to capture statuses electronically (e.g., permit to
        proceed)

    e.  Need ability to pay duties and report electronically on
        inventory shoratages/breakages

    f.  Need a better way is needed to identify a final withdrawal (092)

    g.  What happens to merchandise that never leaves the warehouse?

        i.  Merchandise that stays in the warehouse beyond 5 years it is
            treated like general order merchandise- it becomes the
            property of the government

        ii. This is also a concern for the PGAs

7.  [Parking Lot]{.underline}

    a.  Trade would like to discuss R5 Deployment Plan

    b.  Split shipments

    c.  Entry numbering process

    d.  Port code link to entry number

    e.  Determination of entry acceptance

####### Post Release: Validate Entry Summary - Entry Types - December 1, 2004 

I.  Intro

    A.  Field -- a single piece of information on a screen

    B.  Data object -- like a field, but can be used any where.

    C.  Header level -- information on a document that pertains to
        everything on the document (eg: filer)

    D.  Line item level -- lower level data (eg: HTS)

    E.  Groupings -- categories

    F.  Partners -- types of data that are managed in account
        management, eg: carriers

    G.  Master Data -- used centrally in the system, every area of the
        system can access that record

II. Quota Scenarios

    A.  Filers can make changes to quota information up until
        pre-threshold

    B.  Once at pre-threshold, the broker must make a change request to
        CBP if they want to back out the quota information (note: this
        is not applicable to opening moment).

    C.  For purposes of ACE, CBP would like the ability to back out the
        quota information to remain at the port level (i.e., import
        specialist or someone on the commodity team rather than HQ).
        After quota fills however, only CBP HQ can make changes.

    D.  Once prorated, if the filer determines that they do not want the
        quota, CBP will delete the quota and the ports reject the entry.
        The importer can then determine whether to warehouse or export
        the merchandise.

    E.  Q: How should the system handle this? That is, if the filer no
        longer wants to use the quota and chooses to do something else
        with the merchandise, should the information be resent as a
        request for a different type of entry (that is, a complete
        replacement entry or a different version of the entry) or should
        the filer have the ability to send a message to CBP asking to
        now process this entry differently by replacing/substituting a
        number of different data elements?

        1.  A: Trade perspective: Substitutions might be difficult if
            not impossible because the trade's systems would have to be
            reprogrammed to substitute specific data elements to
            accommodate the different entry type they are now
            requesting. This would cost a fortune for the trade to do.
            The better option is a replacement entry.

        2.  Need system to track when an entry is cancelled and what
            took its place

    F.  Q: With respect to the 10 month correction period for entry
        summary, would this apply to quota?

        1.  A: No. This would not apply to quota because this impacts
            admissibility.

    G.  Q: What kind of messaging would the trade like for notifying
        them that the merchandise is on "quota threshold"?

        1.  A: Trade perspective: There are trade members who only want
            to receive such messages via EDI, and other trade members
            who would also like to see this type of communication via
            the portal, potentially via the SAL.

    H.  For purposes of ABI, the key trigger is the entry type (02) and
        the HTS number. Going forward, the trigger should be HTS and not
        the entry type.

    I.  Q: What happens when there is an associated VISA requirement?

        1.  A: Going forward in ACE, the broker would transmit the HTS
            and visa; the system would check if the they are
            transmitting the visa from an ELVIS country. If so, then the
            system would check to see if the visa is available, and
            proceed with quota processing. If the country is not in
            ELVIS then paper documentation would be required.

    J.  NOTE: for USDA purposes a number of quotas are not tracked by
        CBP; additional input would be required from that agency.

III. [Entry Types]{.underline}

     A.  Entry types existed prior to ACS; their function is not solely
         as triggers for certain types of edits.

     B.  System can route on elements other than entry type, e.g.,
         importer, HTS, etc.

     C.  Legally, CBP cannot do away with paper- CBP must always provide
         that capability; the assumption is however, that the critical
         elements of the paper documentation (e.g., header) will be
         input electronically.

     D.  This raises the following questions:

         1.  Will imaging be used?

         2.  Can CBP route work flows based on entry type?

     E.  System edits for entry types in today's environment are driven
         by specific types of data; they are not limited to entry types

     F.  What is driving the need to consolidate the number of entry
         type codes? In ACE we don't want to rewrite the code over and
         over when it's the same for many entry types.

IV. [DTF]{.underline}

    A.  DTF is based on information driven by HTS (e.g., value, special
        programs, quantities, units of measurement, etc.)

    B.  The programming for ACE must be flexible to allow for
        legislative changes which can occur at any time.

    C.  Normal calculations don't change other than the exception
        programs which are politically driven (e.g., trade bills, tariff
        changes (made several times during the year), AD/CVD)

V.  [7501 Data Matrix]{.underline}:

    A.  Entry number

        1.  The entry number includes the filer number; the filer number
            is generated for the release of cargo.

        2.  NOTE: Recently passed legislation will allow for
            reconfigured entries; this will allow for multiple entry
            numbers for a single transaction (this will require a
            reconfigured numbering scheme). This applies to the IASS,
            which will be delivered in R7.

    B.  Entry date

        1.  Entry date and release date are used interchangeable and
            should not be. Although they can occur at the same time this
            is not always the case.

        2.  The entry date defines the duty rate as defined by the
            regulations (§141.68).

        3.  For quota merchandise the entry date is the time of
            presentation (§141.68).

        4.  For different entry types (e.g., FTZ), the fields can be
            used for different things; in some instances not all of this
            information is transmitted.

        5.  Shipment can be released without being entered, but not vice
            versa

    C.  Port

        1.  Type of Ports (set forth in §101.1):

            a.  Port of Entry

            b.  Port of Filing

            c.  Port of entry

            d.  Processing ports

        2.  Going forward may have multiple ports per line item; there
            are also PGA considerations

        3.  May need to be split to a further level

    D.  Bond type code/Surety code:

        1.  Is this necessary at the header level?

        2.  Is it necessary at all since it is already on file and
            system can do a check for this?

        3.  Need to check with the surety group

        4.  This may be necessary for eBond purposes

        5.  Q: Under what circumstances could we use bond riders to
            obligate the bond?

            a.  A: For purposes of reconciliation

    E.  Ultimate consignee name and address- i.e., Entry Summary
        Ultimate consignee name and address:

        1.  For entry summary purposes, you will always need a name

        2.  For release purpose, can have an address

        3.  A single field which is currently under discussion with CBP
            and needs to be defined

        4.  By law, this field requires the designation of the importer
            of record or other party of interest (§141.19).

    F.  Importer of Record Name and Address

        1.  Q: For legal purposes does it make a difference if the name
            and address don't match to the IR number? A: Yes, it could,
            specifically for purposes of debt collection, bond.

        2.  ACE ID: Record number for SAP that will allow for
            account-based processing.

    G.  Exporting Country

        1.  Outstanding issue: discrepancy between CBP and Commerce with
            respect to the use of the two letter code for country of
            origin

    H.  Export Date

        1.  Trigger for AD/CVD, exchange rates, trade programs, visa
            requirements

    I.  Country of origin:

        1.  Trigger- same as above

        2.  Can have multiple line items per HTS (watches, 9802s)

        3.  Outstanding: country of origin of watches which requires
            separate country of origin breakout per watch component;
            this also impacts DTF calculation

    J.  Missing documents

        1.  Complete documentation is a regulatory requirement. The
            trade has 120 days to submit missing documents; if the trade
            does not comply, liquidated damages are assessed (§141.91).

    K.  IT Dates

        1.  Reflected on the 7501 for purposes of duty (§141.69)

    L.  Mode of Transport

        1.  Related to DTF for purposes of HMF

    M.  Manufacturer ID

        1.  Used to identify the party sending the merchandise (can be
            the supplier, exporter or manufacturer)

        2.  Trigger for AD/CVD

        3.  Problem: the algorithm is generated by CBP based on the name
            and foreign country address; this is a security issue; no
            uniformity of application for this algorithm; different ways
            of interpreting the address

        4.  Census input required on this issue

    N.  Reference Number

        1.  Brokers use this when they file a bond for a company and the
            company wants the broker to handle any problems related to
            the transaction

        2.  Also an indicator when the importer wants any refunds to be
            sent to another address; associates an importer's IR number
            to another party's IR number

    O.  Foreign port of lading

        1.  Army Corps of Engineer is the source for this table (Table
            K); additional data elements are required (currently limited
            to 5 data elements)

    P.  Location of Goods/G.O. No.

        1.  General Order (G.O.) merchandise is assigned a number by
            CBP; when it is taken out, the trade references the G.O.
            number

        2.  General Order merchandise is covered under Part 127 of the
            Regulations

    Q.  Import date

        1.  Triggers: duty, bonded warehouse, TIB

VI. [Triggers]{.underline}

    A.  03 - Consumption (AD/CVD)

        1.  Inputs (i.e., triggers):

            a.  HTS

            b.  Country of origin

            c.  Manufacturer

            d.  Trade agreements/Special programs

            e.  Bonding requirements (check against the single entry
                bond or continuous bond)

            f.  Case number

            g.  Outstanding: how does the "reimbursement clause" fit
                into this? If at the time of liquidation CBP does not
                see a reimbursement certificate, CBP will charge the
                importer double the duties.

        2.  Outputs:

            a.  suspension of liquidation

            b.  unique rejections

            c.  liquidation will require liquidation order; injunction,
                court order, etc.

            d.  \*within the same entry can have an ongoing series of
                inputs and outputs for an entry

        3.  Need electronic mechanism for reimbursement clause

**[Post Release: Validate Entry Summary - Entry Types -- December 2,
2004]{.underline}**

########  **Reconciliation Overview**

a.  The definition and overview of reconciliation was provided by CBP
    HQ.

b.  The Miscellaneous tariff bill provides an extension is the
    reconciliation filing period to 21 months

c.  The TSN requirement recommendations on recon were discussed,
    including:

    i.  Post summary flagging and deflagging

        1.  Deflagging: when blanket flags are set it allows the
            importer to remove specific flags when a determination is
            made that the flag was not necessary

    ii. Retroactive flagging: This is specifically needed for purposes
        of assists. "Assists" are defined in 19 CFR §152.102(a)

    iii. Standard format for spreadsheet included in reconciliation

    iv. EDI download of flagged entries

d.  Outstanding: What will be the CBP policy for automated liquidation-
    when should the clock start?

e.  Outstanding: Can ACE generate the reconciliation or generate the
    spreadsheet and send it back to the trade for verification? Past
    discussions with CBP indicated that this was the filer's
    responsibility and not that of CBP

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II. **[Import Activity Summary Statement (IASS)]{.underline}**

    a.  Not in place today

    b.  Intended to allow importers to roll up a number of releases for
        a given month into one entry summary

    c.  It is a means by which similar commodities can be rolled up into
        one entry summary (e.g., same HTS, country of origin,
        manufacturer, etc.)

        i.  CBP envisions that this will work best for repetitive
            commodities and for border type shipments and truck
            shipments. Can't roll up releases with different vessel
            names

    d.  For legal purposes, that summary is called the "reconfigured
        entry"

    e.  This is a way to marry up the Periodic Monthly Statement with
        the entry summary

    f.  IASS will impact the liquidation time and would give the
        importer the option not to have to file an entry summary within
        10 days from entry, since the IASS is monthly process

    g.  Trade: the way this is envisioned to work is that at the time of
        entry, the commodities will be flagged for IASS

        i.  The trade has also discussed the possibility of allowing the
            system to default to an IASS when the entry summary is not
            filed within the 10 day regulatory time after entry

    h.  Statutory authority for the IASS exists (19 USC 1401(r)) and has
        been further defined in the Miscellaneous Tariff Bill

        i.  Outstanding: Details for qualification are still subject to
            CBP discussion

        ii. Outstanding: Will certain elements of the IASS be worked
            into ACS prior to R7?

        iii. Outstanding: Will CBP run a "test" on IASS when
             appropriate?

    i.  Outstanding: In the future state, when the trade is given the
        option to reconfigure these entries, what will be the legal
        definition of the "entry"?

        i.  The trade will need to keep within the statutory and
            regulatory record keeping requirements (Part 163 of the
            regulations)

        ii. For legal purposes, both the initial document submitted by
            the trade and any additional submitted documentation will
            constitute the "legal document"

    j.  Outstanding: The trade wants to be able to run checks of its
        data against CBPs data- how can we approach this?

        i.  Concerns with system limits to store data

        ii. At what point should information be purged/archived?

III. **[Entry Types]{.underline}**

     a.  Entry type 02

         i.  Trigger: tariff, then the country code, special program
             indicators, date, value

         ii. Inputs: quantity, quota category, VISA \# and MID for VISA.

         iii. Outputs: quota acceptance or rejection message, may also
              need a message that says, we are processing, reviewing,
              etc. Keep in mind the differences between absolute and
              tariff rate. What happens if its absolute and rejected?

         iv. No special class codes for quota.

         v.  Master data: quota master record

     b.  Entry type 03

         i.  Triggers: MID, Special program indicators, HTS, country of
             origin, date of import for AD, date of export for CVD.

         ii. Input: bonding requirements, case number, value, quantity

         iii. Output: suspend liquidation, unique rejection, could
              determine that it doesn't apply, so then the entry type
              changes and it becomes an 01 via a re-file, but with the
              same entry #.

         iv. Want ability to attach statement of non-reimbursement to
             the entry summary, this applies to AD/CVD entries.

         v.  Master data: dumping case file, special bonding conditions.
             The master file for AD is maintained by IA.

         vi. Report would be ideal here to determine what entries are
             sitting out that are not liquidated. Need to have
             retroactive suspension of liquidation. It affects the
             bonding the duties, and the liquidation.

     c.  Entry type 06

         i.  Triggers: entry type,

         ii. FTZs use 2 fields on the Entry summary for things other
             than they are intended. Going forward, we want to remedy
             this so that we are using the appropriate field and so that
             the integrity of reporting is maintained.

         iii. Input: same as any other entry, status is an input to
              determine the duty calculation. Zone number could be a new
              trigger going forward.

         iv. The 06 entry does not specify if it is for quota or not,
             the system knows to check for the HTS and other elements to
             determine if. Zone status is required at the line level. We
             could have an HTS on multiple lines because they could have
             different statuses.

         v.  Output: DTF effects: status, HMF is already paid.

         vi. Master data: status and DTF calculation, HTS and historical
             HTS.

         vii. We can still have an identifier and a way for the system
              to pull up all entries that are AD, but we don't
              necessarily have to have different types of entries. The
              entry type today is used for internal routing and as a
              trigger for what data elements are required. There are no
              time frames on how long something can be in a zone and it
              can even be destroyed in the zone.

     d.  Entry type 07

         i.  Is a combined AD/CVD and quota, system does both sets of
             checks.

     e.  Entry type 11

         i.  Triggers: value, HTS, there are certain implications for
             different agencies,

         ii. Inputs: no bond is required.

         iii. Outputs: liquidation is different.

         iv. Informal has to be live unless they pay on ACH, in which
             case the bond must be present. There are items on the 7501
             that are circled so there are some optional fields.

         v.  DTF: different class code for the MPF. HMF is still there.
             There is an informal entry fee also. Fees are different,
             the duties are the same.

     f.  Entry type 23

         i.  Trigger: entry type

         ii. Input: 98 tariff numbers (it's a 98 provision). Can only
             have TIB on certain HTS numbers

         iii. Output: don't liquidate, date of export of destruction
              within one year unless it's extended. If it's not exported
              or destructed, then the liquidated damages occur. They
              tell us now and it manual that CBP goes in and closes it
              when its exported or destroyed. There is a certain % that
              CBP has to supervise. Have to advise the port it was
              brought in now because it's a paper process today.

         iv. Need a mechanism - Report or message to tell the filer that
             the one year limit is coming up.

         v.  DTF; duty is shown on it, but it's not collected. HMF is
             collected.

         vi. Today, there is not a lot of linking of documents in ACS,
             much of it is done through notes in the system.

         vii. Will comments be allowed in the new system? Yes they can
              be, but the problem with them is reporting, tracking etc.
              have to be used carefully.

         viii. TIBs are provided for in 19 CFR 10.31 through 10.40

         ix. The period of time during which merchandise entered under
             this Chapter 98 provision may remain in CBP territory is
             limited to one year. Some commodities however, are limited
             to limited to 6 months

         x.  The one year period can be extended for not more than two
             further periods of one year (for a total of 3 years), upon
             request

         xi. TIBs do not liquidate because they are not "entered". They
             are closed, and tracked through a report at the port level

         xii. If merchandise is not exported or destroyed within the
              allotted time, liquidated damages are doubled

         xiii. Merchandise must be exported or destroyed within the
               allotted one year (unless an extension has been granted).
               The clock starts one year from the import date

         xiv. If merchandise is destroyed, and if a determination is
              made that there is valuable waste, the importer is
              responsible for payment of duties and fees

         xv. Anticipatory breach (19 CFR 10.39(f)) allows the importer
             to advise CBP that the merchandise entered under TIB will
             not be exported or destroyed in accordance will the terms
             of the bond. At that time the importer must pay to CBP the
             liquidated damages that would be assessed at the time of
             the breach of the bond and the entry is closed.

     g.  Entry type 24 (Trade Fair)

         i.  Need to submit a letter of intent and give a time frame and
             file a 7501. Trade fair operator makes the entry.

     h.  Entry type 25 (Permanent Exhibition)

         i.  5 years, this is used a lot for artwork, museum, etc.
             Importers don't have to pay the duty as long as it stays in
             the country for 5 years or more.

         ii. These are all paper today.

     i.  Entry type 21 (Warehouse)

         i.  Trigger: entry type

         ii. Inputs: destination warehouse (goes in the location of good
             field), really have two data elements in one field. Also
             put pieces quantity on this. DTF is calculated, only the
             HMF is collected. After 5 years, it becomes the property of
             the government, is processes like general order
             merchandise.

         iii. Quota is reported when it comes out on the withdrawal.

         iv. There are times when its going in and it has the visa, even
             though they don't have to until the time it comes out.
             Sometimes the port will certify at entry, and then they
             give it back and have a copy at the port and then they can
             make the subsequent withdrawals, this would be on the line
             items not the header.

         v.  Might want to consider having internal notes and external
             type notes that the trade can

         vi. Do we want to use exception reporting to scan for things
             that have passed their time limit. Could be managed through
             workflow.

         vii. DTF: HMF only

         viii. We need an indicator that the final withdrawal is done.
               Explosives and perishables cant enter the whse. HTS check
               as far as possible to check for this, its not all
               inclusive.

     j.  Entry type 52

         i.  There are specific edits in there that are exclusive to
             govt agencies

     k.  Entry types 67-69

         i.  Done on 7512.

         ii. Have an opportunity to automate a lot of these that are not
             electronic, have to decide for the ones that have to remain
             this way, and how to key those in. Also have to look at
             practicality.

     l.  Entry type 81

         i.  The 81 was created to hold the place for the automated 214
             that hasn't happened yet. Manifest uses some of these entry
             type codes as indictors. Maybe it could be done on a
             modified 7501.

     m.  Warehouse withdrawal for consumption:

         i.  Trigger: entry type

         ii. Input: original warehouse entry, indicator when it's the
             final withdrawal.

         iii. When CBP gets the final withdrawal, it knows to go back
              and liquidate the warehouse entry.

         iv. There is a report in ACS for the final warehouse
             withdrawals.

         v.  DTF: HMF was already paid. The duty is calculated based on
             when its coming withdrawn