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April 2026, question 25

Practical Exercise · ACE entry summary data and business rules

Facts for questions 24 to 26, as CBP printed them:

As in the real world where client documents may contain errors, the practical exercise documents may contain errors. Examinees should review the documentation carefully and identify any errors. Any errors in the documentation should be taken into account when selecting an answer.

Answer questions 24-26 based upon the facts and CBP Form 5106 below. The form has been modified to only include portions relevant to answering the questions.

Zurefire EV, a division of Zurefire Motor Company, intends to be a consignee on future import transactions and has asked Okay Customs Brokers (Okay CB) to obtain an importer of record number for them using the parent company’s EIN as the first nine digits and adding a two-digit suffix. The form as shown was submitted to Okay CB as shown with Section 4 incomplete in an email from the President of Zurefire Motor Company, Eloise Smelly. After verifying the accuracy of the data with Ms. Smelly, Entry Writer Candy Dunn of Okay CB will use ABI to input the data. The license qualifier for Okay CB, Justin Time, also verified that Okay CB has the authority to add or change the importer’s data under the power of attorney with Zurefire Motor Company that Mr. Time endorsed on behalf of Okay CB.

DEPARTMENT OF HOMELAND SECURITY U.S. Customs and Border Protection

CREATE/UPDATE IMPORTER IDENTITY FORM 19 CFR 24.5

As the importer, consignee, or other party listed in block 1, you are responsible for the validity of the information provided in this document. Any Customs Broker or third party who is submitting the information on your behalf is only obligated to convey this information to Customs and Border Protection (CBP).

INSTRUCTIONS

TYPE OF ACTION

Notification of Identification Number – Check this box if this is your first request for services with CBP, or if your current Importer Number is inactive and you wish to activate this number. Change of Name – Check this box if the Importer Number is on file but there is a change in the name. Change of Address – Check this box if the Importer Number is on file but there is a change in the address. For updates involving to an existing IOR other than a change of name or address, “TYPE OF ACTION” should be left blank. NOTE: If a “Change of Address” and/or “Change of Name” is requested for an importer or other party that has an active bond on file with CBO, then a name and/or address rider must accompany this change document, unless the rider is otherwise not required for the bond pursuant to a CBP test announced in the Federal Register, such as CBP’s eBond Test Program, or otherwise not required by CBP’s regulations. SECTION 1 – NAME AND IDENTIFICATION NUMBER 1A – Importer/Business/Private Name – Indicate the full legal name of the company or individual who will be importing or seeking service or payment. If you are submitting this document as a consignee to the import transaction, sections 1 and 2 must be filled out completely. 1B – IRS/SSN – Complete this block if you are assigned an Internal Revenue Service (IRS) employer identification number or Social Security Number (SSN). If neither an IRS employer identification number nor a Social Security Number (SSN) has been assigned, click the “NONE” check box. The SSN should belong to the principal or owner of the company. 1C – DIV/AKA/DBA – Complete this block if an importer is a division of another company (DIV), is also known under another name (AKA), or conducts business under another name (DBA). 1D – Complete this block only if Block 1C is used. SECTION 3 – COMPANY INFORMATION – In most cases, the data elements in this section are optional. However, if the “I have a SSN, but wish to use a CBP-assigned number on all my entry documents” option was selected in block 1E, you must provide your Company Position Title, Name, and SSN in Block 3J. The absence of this information will affect CBP’s ability to fully understand the level of risk on subsequent transactions and could result in the delay of cargo release or the processing of a refund.

3A – Provide a brief description of your business. 3B – Complete this field if you know the North American Industry Classification System (NAICS) code as defined by the Department of Commerce. Provide your 6-digit NAICS code. 3C – If available, provide the Dun & Bradsheet Number for the name that was presented in section 1. 3D – If you are an importer who is a self-filer and are using your own filer code, or a broker who also has maintained an identification number, provide the filer code that you will be using to conduct business with CBP. 3E – Indicate the year in which your company was established. 3F – Related Business Information – List the name and IRS employer identification number, Social Security Number or CBP assigned number for each related business and indicate if it is a current or previous related business. 3G – Indicate the primary banking information for the company that is listed in section 1. 3H – Certificate or Articles of Incorporation – Provide the 2-digit State or insert a 2-character alphabetic ISO Code representing the country in which the articles of incorporation for the business were filed (as applicable). 3I – Certificate or Articles of Incorporation – Provide the file, reference, entity, issuance or unique identifying number for the certificate or articles of incorporation or business registration number or the foreign articles of incorporation (as applicable). 3J – Business Structure/Beneficial Owner/Company Officer – The Beneficial Owner is any individual or group of individuals that, either directly or indirectly, has the power to vote or influence the transaction decisions regarding a specific security or one who has the benefits of ownership of a Security (finance) or property and yet does not nominally own the asset itself. Beneficial Owner/ Company Officers must have importing and financial business knowledge of the company listed in section 1 and the legal authority to make decisions on behalf of the company listed in section 1 with respect to that knowledge. In most instances, the SSN or Passport

PAPERWORK REDUCTION ACT STATEMENT: An agency may not conduct or sponsor an information collection and a person is not required to respond to this information unless it displays a current valid OMB control number and an expiration date. The control number for this collection is 1651-0064. The estimated average time to complete this application is 45 minutes. The obligation to respond is required to obtain a benefit. If you have any comments regarding the burden estimate you can write to U.S. Customs and Border Protection, Office of International Trade, Regulations and Rulings, 90 K Street NE, Washington DC 20299-1177.

If data is required in Blocks 1C and 1D, which of the following choices will correctly identify the data needed to complete those Blocks?

  1. Data is not required in Blocks 1C and 1D because there is no red asterisk next to the block number.
  2. Mark DIV in 1C and type Zurefire Motor Company in 1D.
  3. Mark DIV in 1C and type Zurefire EV in 1D
  4. Mark DBA in 1C and type Zurefire Motor Company DBA Zurefire EV in 1D
Page from CBP's April 2026 exam booklet for question 25
Page from CBP's April 2026 exam booklet for question 25
Page from CBP's April 2026 exam booklet for question 25
Page from CBP's April 2026 exam booklet for question 25
Page from CBP's April 2026 exam booklet for question 25
Show the answer and walk-through

CBP's answer: B. B: Mark DIV in 1C and type Zurefire Motor Company in 1D.

Zurefire EV is a division of Zurefire Motor Company and uses the parent's EIN with a suffix. For a division the BRPD steps say to select DIV in block 1C and give the official legal name of the parent company in block 1D, so Zurefire Motor Company goes in 1D and B is right. Block 1D must be completed whenever 1C is used, so A is wrong, and 1D takes the parent's name rather than the division's.

Under block 1D, provide the official legal name of the entity (parent company). ACE BRPD Section 23.9

Search for: DIV, AKA, and DBA IOR's

CBP's key cites: ACE BRPD Section 23.10

Question and key from CBP's April 2026 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).