Minutes – Conference Call by absences

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									                                    Release 5 Business Blueprint
                             Trade Engagement Bi-Weekly Activity Report
                                Reporting Period: January 3 – 14, 2005



1. Account Management
      a. January 4: Data Validation
              i. Trade Participants: Don Huber, Stuart Schmidt
      b. January 6: SAP Master Data, Business Partner Design
              i. No trade participants
      c. January 11: Program Participation
              i. Trade Participants: Don Huber, Stuart Schmidt, Jevon Jamieson
2. Post Release
      a. January 5: Team Review I
             i. No trade participants

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Account Management: Data Validation Workshop
                January 4, 2005
Duplicate Checks
Unique Identifiers for a brand new company:
       EIN/SSN
             o EIN can be duplicated on multiple Importer records
       IR# -
             o Cannot be duplicated. Each Importer record has a unique IR#
       Name
             o Name can be duplicated on multiple Importer records
             o The duplicate check would need to utilize “fuzzy” logic to identify possible
               duplicates based on variations of the spelling of the name
       Address (physical & mailing)
             o Mailing address will be duplicated on multiple Importer records more
                                         May 13, 2004
               frequently than the physical address
             o The recommendation is to use the physical address when performing the
               duplicate check
             o The duplicate check would need to utilize “fuzzy” logic to identify possible
               duplicates based on variations of the spelling of the address
What data elements will be used to determine duplicates or possible duplicates?
       EIN/SSN
       Name


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       Physical address
Trade Comment: The combination of physical address & name will identify most of the
duplicates/possible duplicates. The EIN/SSN can be used as an additional layer of
duplicate check.
Who is notified of the duplicate/possible duplicate account information?
       The process will be similar to the following:
            o New account data is submitted (by Trade/CBP)
            o ACE identifies duplicate/possible duplicate account information
            o ACE notifies the sender that the t information is an exact duplicate or is a
              possible duplicate (list of possible duplicate accounts will be provided)
            o Sender will then do one of the following:
                        Cancel out of the process if they determine that they have sent
                         duplicate information
                        Modify the original submission to make it unique
                        Acknowledge the notification and ACE will accept the information
                         as originally submitted
Today, ABI filers can query ACS by EIN without the IR# suffix (e.g. a wildcard search) to
see if an importer of record is already on file. The query will return the full IR#, name
and address information for every importer record on file that matches the EIN portion of
the IR#.

In the possible duplicate account scenario, there may be an issue with ACE providing a
list of accounts to a broker (or other third party) who is attempting to create account
information on behalf of that entity. See Action Item #1.
CBP Account Managers will be notified when importer of record information has been
added or modified on an account they are managing. There will be an additional
notification to the CBP Account Manager if the new or modified information has created
a duplicate or possible duplicate.         May 13, 2004

There was a recommendation to do trend tracking to identify entities that may be
entering and acknowledging duplicate/possible duplicate information on a regular basis.
ACE will not systematically force an entity to perform due diligence in preventing
duplicate information. If need be, ACE could notify CBP when it has identified a
potential abuser. See Action Item #2.

In the situations where there is a request for a port generated IR #, ACE will reject the
request when there is an exact match on name and physical address. What information


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will ACE provide back to the sender in the case of a duplicate? Do we provide them with
the IR number that is already on file? See Action Item #3.

NOTE: An off-topic discussion developed regarding the possibility of ACE generating
all new IR numbers in the future. There is a TSN requirement that requests that the
future IR numbers not be a derivation of the EIN/SSN. There are concerns from some of
the trade community, PGAs and CBP that by removing EIN/SSN from the IR# it may
complicate their ability to identify related companies, business units, etc. This concern is
noted and will be considered when developing the solution for the IR# format of the
future.
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Currently in ACE, nothing gets into the Trade‟s Account Tree structure until the CBP
Account Manager approves the change. This means that the Trade cannot query or run
reports on the new data until the CBP Account Manager does an approval. The
recommendation is to loosen this restriction in the future and change the process to be
a notification to the CBP Account Manager when there is a change and the change
would take effect immediately without an approval being required.

Today in ACE, every Account has a CBP Account Manager assigned to it. In the future,
this is not going to be the case…will we need to have two separate sets of rules in the
notification structure?

Trade would like to know if a broker is trying to establish an account for someone that
they already have in their tree. They would like this notification for both domestic and
foreign entries.

Address Validation
       Address standardization
            o The standardization will be based on current CBP policy and directives
            o The system could automatically correct standardization issues. See Action
              Item #5                 May 13, 2004

                        The Trade would like to see the correction and have the ability to
                         accept the change or override it
                        This could be a workable solution via the portal
                        We will have to determine what the best solution will be for handling
                         data that is submitted via EDI
       Address verification
            o Verifying the physical address


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                        Hard Error - ACE will reject invalid city, invalid state/province,
                         invalid postal code, invalid country and invalid combinations of city,
                         state, postal code, country etc.
                        Soft Error - ACE will require an acknowledgement from the sender
                         when ACE cannot verify that a street address exists. The sender
                         will then do one of the following:
                                Correct the address information if there was a keying error
                                Acknowledge the notification and ACE will accept the
                                 information as originally submitted
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                                Cancel the request
            o Verifying the mailing address
                        Hard Error - ACE will reject invalid city, invalid state/province,
                         invalid postal code, invalid country and invalid combinations of city,
                         state, postal code, country etc.
Q: Trade would have to respond to both the hard & soft error. Does CBP need to get
involved? If so, how much involvement?
A: CBP does not have to follow up on the Hard Error, because the system will not
accept it until the trade makes the required corrections. CBP may need to follow up on
the soft errors. ACE could send notification to a CBP Account Manager or another CBP
role if an Account Manager has not been assigned.

To what extent do we verify foreign address? See Action Item #4.

Trade recommends that the address fields (e.g. a free form line) have to be able to hold
all of the information that trade requires. For example, a company may need PO Box
123, Customs, Room # 142. Currently, ACE will not accept anything other than a PO
Box, and this would cause the mailing to go to the wrong address or be returned.
Mailing addresses must be used by CBP in total. Limitations today are with the post
                                            issue. 2004
office box. Suite versus room is also anMay 13, ACE uses „ste‟ as the abbreviation and
mail rooms would not know what that is.

Trade Changes to Data Elements That Will Require CBP Action
CBP ACTIONS:
       Approval – A CBP role (e.g. Account Manager) will be required to approve the
        change prior to the change becoming effective in ACE. Comment: In the past,
        Trade has had an issue with CBP approval, because if the Account Manager is
        out for an extended period of time, that’s how long the trade has to wait for
        approval. eCP believes that the workflow functionality will solve this issue by
        forwarding issues to a CBP role identified as the backup.

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      Acknowledgement – A CBP role will be notified that a change has been made
       and would be required to “acknowledge” the notification (e.g. by clicking an “OK”
       button). The change would not be affected by the acknowledgement and would
       take effect immediately.
      Notification – A CBP role will be notified that a change has been made. The
       change would take effect immediately.
Changes to the Account Tree
      Merger/Acquisition/Divesture
           o Moving all or portions of one account to another account would require
                                              t
             CBP approval
      Adding new data (new IR#, new filer code, etc.)
            o CBP will be notified
      Change to the account structure (e.g. moving an IR# from one division to
       another within the same account)
            o CBP will be notified
      Change to company name
            o Require CBP acknowledgement
      An importer will be notified when a third-party (broker) adds a new suffix to an
       existing EIN already associated to that importer‟s account.

How are unmanaged accounts going to work in regards to account approvals for
mergers/acquisitions? See Action Item 7.

EIN/SSN Verification
      Verify with the Internal Revenue Service (IRS) and the Social Security
       Administration (SSA) that the EIN/SSN was issued to the named entity. This is
                                         May 13, 2004
       an outstanding legal policy questions.
      Validate EIN/SSN – ACE can determine that the EIN/SSN is a valid number but
       would not verify that the number was issued to the named entity.

Background Investigations & Premise Inspections
CBP does premise inspections and background investigations prior to the approval of a
bonded facility.
Background investigations are done before a Customs Broker License is issued.
ACE will record the date when the premise inspection was completed.
ACE will record the date when the background investigation was completed.

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Does CBP conduct premise inspections at duty-free shops?

Action Items:
   1. What information should ACE provide to a third party (e.g. Broker) in the instance
      where a potential duplicate has been identified?
   2. Will the Broker Management Office want a report that identifies which brokers are
      entering duplicate importer account data?
   3. ACE will reject the request to create a “port assigned” IR# when there is an exact
      match on name and physical address. When notifying the sender of the
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      duplicate, can ACE also send the IR# that is already on file for the name/address
      match?
   4. To what extent do we verify foreign address?
   5. Do we let ACE automatically convert common spelling variations when it can
      correct them, and just accept those as being correct? Or should we give the
      trade the option of whether to accept the change that ACE has made?
   6. Don Huber will check with his tax office to find out more information on how often
      tax IDs are changed.
   7. How are unmanaged accounts going to work in regards to account approvals for
      things such as changes in structure?



         SAP Master Data, Business Partner Design
                 January 6, 2005
Creation of New Accounts in SAP
                 Need an additional Business Partner role, Credit Management, for
                   Bond Management and Bond Sufficiency
                                            May 13, 2004
SAP Business Partner
               Name field – request by Trade to be able to put in multiple lines for
                  the same IR number. This refers to multiple DIVs, DBAs and
                  AKAs.
               Need the ability to handle one or many names
               Address types – need the ability to handle one or many
               All fields from the address must copy to the mailings.
               Terms such as Suite, should not be abbreviated




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                       Mailing address could change depending on the port. If the mailing
                        is related to a particular transaction, it would be sent to the broker‟s
                        office at the port.
                       Need to verify trade‟s request for a “care of” field.
                       Need to accommodate the use of both the PO Box and the Street
                        Address together.

ID Tab
                       Do truck carriers need multiple fields for insurance? Currently ACE
                        is capturing information for one insurance company. Trade would
                        like multiple fields.      t
                       Is more than one DOT number per SCAC needed?

Control Tab Data
                       Trade Ambassadors have stated that the name filed of 32
                        characters in ACS is not enough.

One-time Accounts/Informals
                Walk-ins at the border – what is recorded for these shipments
                   (informals)? Do they have to fill out a 5106?


                            Program Participation
                              January 11, 2005
Importer Self Assessment (ISA)
ISA is a voluntary program for importers. A prerequisite to participation in ISA is
C-TPAT.
                  Importers submit a written application to CBP to participate in the
                     program.
                  CBP conducts an onsite13, 2004
                                        May inspection.
                  The ISA Board meets monthly to consider new applicants for the
                     program.
                  Importer sends an annual report to CBP affirming they are following
                     the processes and procedures established.
                  iTRAC data is free to ISA participants.
                  CBP has established guidelines under which an importer can be
                     removed from the program.
                  The importer can opt out of the program at any time.

ACE should capture the following statuses:

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                        Application received
                        Application rejected
                        Application resubmitted
                        Audit was scheduled/completed
                        Company approved
                        Annual report is due/received
                        Flag for ISA participation should be set at the IR level.
                        Group field to list all IR numbers included in the ISA
                        Program participation ceased (IR level)
                        ISA point of contact         t

Since the trade is generating the report, what part of the process should be automated?

Is there an ISA similar program under consideration for brokers?

The broker could act as a participant to assist the importer. That is, the broker could be
doing the checks and balances for the importer with oversight by the importer. The
broker could also write the policies and procedures for the importer. Brokers can do
that today if they have a national permit. The broker could also be the one to prepare
the final report. Would CBP care who all is involved in the preparation of the report?
Would they want to capture third party participation?

Remote Location Filing (RLF)
RLF is a voluntary program for brokers. A national permit is a prerequisite for this
program. RLF is a one step process.
                  Technically RLF could be considered a release program.
                  The CF 3461 and the CF 7501 are submitted together or the filer
                    can certify from the summary.
                  The commercial invoice is optional as part of the initial transmission
                    except in the border environment where it is always required.
                  The commercial invoice 13, 2004 presented if requested.
                                        May must be
                  Broker submits a letter of request (mail, fax or email) to CBP to
                    participate in RLF.
                  Additional ABI testing must be completed.
                  Approval is on a port by port basis.
                  Participation could be captured as part of the EDI profile
                    established.

Is the application process needed if the broker has a national permit?




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Currently RLF is available for entry type 01 and 11 only. The trade has requirements to
expand RLF to all entry types and in-bond shipments. Current restrictions go against
the natural flow of logistics. RLF works for ocean shipments but not air where freight is
normally cleared at destination.

Self filers would not have to go through the national permit process but they do have to
pass the ABI testing requirements.

Nuances of RLF: The broker can designate an exam site on a transactional level. The
freight is not under the carrier‟s bond but under the importer‟s bond. The request for the
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exam at a certain location can be denied. Designation is by FIRMS code. That
capability may go away in the future.

Customs and Trade Partnership Against Terrorism (C-TPAT)
 C-TPAT - Importer
  CBP is planning on creating an online application. Upon submission of the
  application the company becomes certified as a member of the program. The
  company would become verified after the formal inspection has taken place. The
  verification team will visit both a US and foreign site to ensure the site is secure and
  procedures are being followed. A report is then prepared.

   C-TPAT – Carrier
    Address information on all terminal locations must be provided. The whole process
    is very time consuming; it takes approximately four months to gather all the needed
    information. The process varies by mode of transportation. Jevon reported
    submitting terminal address changes but not receiving a response from CBP.

   C-TPAT – Broker
    The application process for the broker is the same as for the importer with the
    exception of having to provide supplier information. To date no brokers have been
    verified as C-TPAT. The trade believes this is a matter of workload priority for CBP.
                                            May 13, 2004
Is there a C-TPAT program for foreign trade zones or bonded warehouses?

Who maintains the C-TPAT information?

Trade needs to make certain they follow up on their application with the C-TPAT office.
Because of the large number of applications, C-TPAT staff does not have time to follow
up with the trade concerning missing information on the application.

PGA Programs



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Since there were no PGA representatives at the workshop, the Account Team will follow
up with the ITDS Team to define PGA needs.

Jevon made the point that in future releases CBP needs to work more closely with
PGAs to synch up changes to systems/policies.

Release 4 Program Participation
Currently whatever is captured in ACE under CBP Program Participation will roll to
Release 5. Some of the programs listed may appear in another category rather than
listed under CBP program participation in Release 5. CBP needs to include this on the
                                              t
tip sheet for changes from one Release to another.

Action Items:
   1. What are the future plans/visions for the ISA program? Are there any plans to
       expand it to brokers?
   2. Should ACE capture information on who was involved in the ISA process? (i.e. If
       the importer were to hire a broker as a consultant.)
   3. How does OST think the ISA program can be automated?
   4. Set up meeting with the Post-Release Team to discuss RLF.
   5. Set up meetings with the ISA and C-TPAT program teams at headquarters.
   6. Follow up with ITDS Team on PGA programs.



                                         Team Review I
                                        January 5, 2005
Paperless entries under ACE will be completely electronic.

Changes made to the electronic entry summary will be sufficient in the future.
   Any change, financial or not, will result in a “change liquidation”.
                                             May 13, 2004
The paper Customs Form will only be required if CBP cannot send the electronic
version; the electronic notification will be considered sufficient notice.

Release 5 will provide ability to capture reason codes per line item for rejections.

Paper documents will only be required in ACE if an electronic version of the document
is not available. This includes applicable licenses, permits, certificates and visas.

An entry summary is considered accepted when the ABI transmission is accepted
without error systematically.

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When an entry summary is changed, notice is sent to the filer. ACE will auto-populate
the notification and send electronically to the appropriate parties.




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                                            May 13, 2004




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