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October 2025, question 14

Broker Compliance · Broker licensing and duties

Andrew Balder, an employee of PM Morris Customs Brokerage (MCB), has decided to import dual color lapel men’s dress jackets to take advantage of their exploding popularity. One of MCB's clients regularly imports comparable dress jackets and has a record number of sales. Which of the following statements is CORRECT?

  1. Andrew Balder may not import items similar to that of MCB's clients because it would be a conflict of interest.
  2. An employee of a broker may not also be an importer.
  3. Andrew Balder must notify the appropriate Center Director and seek permission to import such articles.
  4. Andrew Balder must notify the MCB's client that they are also going to import dual color lapel men’s dress jackets.
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CBP's answer: D. D: Andrew Balder must notify the MCB's client that they are also going to import dual color lapel men’s dress jackets.

Section 111.31(c) says a broker who imports merchandise of the same general character as a client's may not act as broker for that client unless the client has full knowledge of the facts, and the same applies if a broker's employee is an importer. So Balder must tell the client (D). The regulation does not bar an employee from importing, and does not require permission from the Center director.

The same restriction will apply if a broker's employee is an importer. 19 CFR 111.31(c)
unless the client has full knowledge of the facts 19 CFR 111.31(c)

Search for: Importations by broker or employee

CBP's key cites: 19 CFR 111.31(c)

Question and key from CBP's October 2025 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).