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October 2024, question 2
Broker Compliance · Broker licensing and duties
Who must exercise responsible supervision and control over the transaction of customs business of an association or corporation that is a broker?
- All employees of a licensed association or corporation who also hold a customs broker license.
- Only licensed employees who are also the license qualifier and/or permit qualifier for the association or corporation.
- Every officer of a licensed association or corporation, even if the officer is not a licensed broker.
- Every licensed officer of a licensed association or corporation.
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CBP's answer: D. D: Every licensed officer of a licensed association or corporation.
Section 111.28(a) puts responsible supervision and control on every licensed officer of an association or corporation that is a broker. It reaches licensed officers, not all licensed employees and not unlicensed officers, and it is not limited to the license or permit qualifier. That is D.
every licensed officer of an association or corporation that is a broker must exercise responsible supervision and control 19 CFR 111.28(a)
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CBP's key cites: 19 CFR 111.28(a); 19 CFR 111.1
Question and key from CBP's October 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).