CustomsBrokerLicenseExam

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October 2025, question 7

Broker Compliance · Broker licensing and duties

ZX Customs Brokers, Inc. (ZX) is a customs broker that is a corporation. George Forest, an individually licensed customs broker, is ZX’s Vice President of Compliance and is the qualifier for ZX’s license and national permit. On May 1, 2025, the Executive Director, Office of Trade, CBP accepts Mr. Forest’s voluntary suspension of his individual license for one year effective May 5, 2025 due to health issues. ZX’s Import Manager, Jayne Smythe, is an individually licensed broker, but she is not a duly appointed officer of ZX. Which of the following statements is FALSE?

  1. ZX may notify CBP that it is appointing Import Manager Smythe as its national permit qualifier and continue conducting customs business until the annual permit expires on December 31, 2025.
  2. ZX may make a written voluntary offer of suspension of its broker’s license and permit for one year to accommodate Mr. Forest’s voluntary suspension of his license and discontinue conducting customs business during the suspension period.
  3. ZX may appoint Import Manager Smythe as Vice President of Import Compliance, notify CBP that Ms. Smythe will be the new license and permit qualifier effective May 5, 2025, and continue conducting customs business.
  4. Prior to September 2, 2025, ZX may hire Dr. Hu, an individually licensed broker, as its Vice President of Import Compliance. It can then designate Dr. Hu to act as the corporation's new license qualifier and Import Manager Smythe to serve as its new national permit qualifier. After informing CBP of the appointments and complying with all other relevant requirements, it may continue conducting customs business.
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CBP's answer: A. A: ZX may notify CBP that it is appointing Import Manager Smythe as its national permit qualifier and continue conducting customs business until the annual permit expires on December 31, 2025.

The question asks for the false statement, which is A. A corporation needs at least one officer who is a broker (111.11(c)(2)), and Smythe is not an officer, so naming her only as permit qualifier does not fill the license qualifier role. With Forest suspended the corporation would have no licensed officer, and under 111.45(a) a 120-day gap revokes the license and permit by operation of law, so ZX cannot just keep operating to December 31. B uses voluntary suspension (111.52), C and D appoint a licensed officer in time (120 days from May 5 ends September 2, 2025).

Have at least one officer who is a broker. 19 CFR 111.11(c)(2)
fails to have, during any continuous period of 120 days, at least one member of the partnership or at least one officer of the association or corporation who holds a valid individual broker's license 19 CFR 111.45(a)
may accept a broker's written voluntary offer of suspension of the broker's license or permit for a specific period of time 19 CFR 111.52

Search for: at least one officer who is a broker

CBP's key cites: 19 CFR 111.52; 19 CFR 111.11(c); 19 CFR 111.19; 19 CFR 111.45

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).