Broker Compliance · CBLE study guide
Recordkeeping
What records, who keeps them, how long, how to produce them.
- 36past questions in CBLE Pass
- ≈2questions on a typical 80-question exam
- 19 CFR 111.21-111.25, Part 163where 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.
Mixing up retention periods
“A familiar number (5 years, 90 days) applies to every record type.”
The rule: The general rule is 5 years, with listed exceptions: drawback records to the 3rd anniversary of payment; packing lists 60 days; nominal consignee informal entries 2 years; 1321 de minimis records 2 years.
Remember: Learn 163.4(b) as a list of exceptions to the 5-year default.
19 CFR 163.4
Who may see confidential client records
“Business partners on the shipment (forwarder, exporter) or other clients may see a client's records.”
The rule: Client records may be disclosed only to the client, the client's surety on a particular entry, and DHS or other accredited U.S. officers, unless there is a subpoena or court order or written client authorization. Information open to the public is not covered.
Remember: Client, surety on that entry, government. Everyone else needs written authorization.
19 CFR 111.24
Breach reporting: channel and deadline
“Breach notices go to the processing Center or the Executive Assistant Commissioner, or must also be mailed.”
The rule: Notify CBP SOC electronically (cbpsoc@cbp.dhs.gov) within 72 hours of discovery, with known compromised importer numbers; send any update list within 10 business days.
Remember: SOC, electronic, 72 hours. The 10 business days is only for the follow-up list.
19 CFR 111.21(b)
Recordkeeping penalties: negligent vs. willful
“Negligence draws the willful-failure penalty, or causes abandonment or permit suspension.”
The rule: Willful failure: up to $100,000 or 75% of value per release, whichever is less. Negligence: up to $10,000 or 40%. If the record concerns a column 1 special rate, unliquidated entries are liquidated at the general rate in addition to the penalty.
Remember: Willful 100k/75%; negligent 10k/40%; plus loss of the special rate.
19 CFR 163.6(b)
Alternative record storage notice
“The broker asks permission from headquarters, or notifies after switching.”
The rule: Give advance written notice to Regulatory Audit, Charlotte, NC, at least 30 calendar days before using an alternative storage method.
Remember: Charlotte, advance notice, 30 days before.
19 CFR 163.5(b)(1)
Records-request deadline
“The broker has 10, 15 or 60 days to produce records.”
The rule: The designated recordkeeping contact must make records available within 30 calendar days of a DHS request, unless DHS allows longer.
Remember: 30 calendar days, or longer if DHS says so.
19 CFR 111.25(b)
Try a past question
October 2026 CBLE, question 16
CBP provided XYZ Brokers with a written demand to produce entry records related to the eligibility of unliquidated entries for a column 1 special rate of duty in the Harmonized Tariff Schedule (HTSUS). If XYZ Brokers fails to timely produce the requested records as a result of negligence, which penalty may CBP impose, absent any exceptions?
Show the answer and why
A. Correct. When a demanded record relates to a column 1 special rate, unliquidated entries are liquidated at the column 1 general rate (19 CFR 163.6(b)(2)(i)(A)), in addition to the negligence penalty (19 CFR 163.6(b)(1)(ii)).
B. Incorrect. Failure to produce records does not cause abandonment.
C. Incorrect. Permit suspension is not a remedy under 163.6.
D. Incorrect. $100,000 / 75% is the cap for willful failure; negligence is capped at $10,000 or 40% (19 CFR 163.6(b)(1)).
19 CFR 163.6(b) · law as of 2026-11-09
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