Broker Compliance · CBLE study guide
Broker duties & responsible supervision
Responsible supervision and control, client relations, diligence, conflicts, prohibited acts.
- 50past questions in CBLE Pass
- ≈3questions on a typical 80-question exam
- 19 CFR 111.28-111.41where the rules live
Common traps
Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.
What signals a supervision failure
“An office without an on-site licensed broker is automatically a supervision failure.”
The rule: Responsible supervision and control is judged on listed factors, including supervisory visits to offices without a licensed broker. Failing to keep a reachable point of contact current is a clear failure.
Remember: Look for an unmet duty (e.g., point of contact), not merely an unusual arrangement.
19 CFR 111.28(a) · 19 CFR 111.3(b)
Who carries the supervision duty in an organization
“Only the license or permit qualifier, or every officer even if unlicensed, must supervise.”
The rule: Every licensed member of a partnership broker and every licensed officer of an association or corporation broker must exercise responsible supervision and control.
Remember: The duty attaches to licensed members/officers, not to job titles.
19 CFR 111.28(a)
Late client payment
“The broker may hold, return, or net its fee from a late duty payment.”
The rule: Payments received from a client after the due date must be transmitted to the Government within 5 working days of receipt.
Remember: Duty money goes to CBP within 5 working days; fees are a separate matter.
19 CFR 111.29(a)
Freight forwarder referral rules
“POAs may be routed through the forwarder, the forwarder may control communications, or any referral benefit is barred.”
The rule: A broker may pay a forwarder for referrals if the importer is told the broker's name in advance, the broker sends its charges directly, and the broker executes the POA directly with the importer. The agreement may not prevent direct broker-importer communication.
Remember: Referral fees OK; POA and communication stay direct.
19 CFR 111.36(b)-(c)
Locating broker rules by section
“Neighboring section numbers hold the rule.”
The rule: Know the map: 111.37 misuse of license; 111.21–111.24 records and confidentiality; 112.12 carrier/freight forwarder bonding application; Appendix to Part 163 the (a)(1)(A) list.
Remember: Memorize the section map.
19 CFR 111.37 · 19 CFR 111.21 · 19 CFR 112.12 · 19 CFR Part 163, Appendix
Notice to client of method of payment
“The notice must appear on every invoice, or is not required at all.”
The rule: The notice must be on or attached to any POA the broker provides to a client, and it must be given to each active client at least once in every 12-month period.
Remember: On the POA, plus once every 12 months.
19 CFR 111.29(b)
Try a past question
October 2026 CBLE, question 12
Which ONE of the following business relationships is prohibited for customs brokers?
Show the answer and why
A. Allowed. Paying a forwarder's freight charges on behalf of the client is not sharing customs-business fees.
B. Allowed. CBP regulations do not set broker fees.
C. Correct (prohibited). Fees from customs business may not inure to an unlicensed person; the only referral-compensation exception is for freight forwarders (19 CFR 111.36(b)-(c)).
D. Allowed. Brokers may charge for services such as advancing duties.
19 CFR 111.36(b)-(c) · law as of 2026-11-09
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