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April 2026, question 6
Broker Compliance · Penalties, recordkeeping and prior disclosure
Which ONE of the following four scenarios best demonstrates proper compliance with a record examination request? Assume that duly accredited representatives of the U.S. Department of Homeland Security (DHS) made each of the requests below.
- A customs broker receives a request to inspect records relating to a client that the broker stopped working with over five years ago. The broker has maintained the requested records but informs DHS that they will not make the records available for inspection because the period of retention has ended.
- A customs broker receives a request to inspect records relating to a particular entry of merchandise from an entry made two years ago. The broker mails the original paper version of the requested records to DHS, postmarked 60 calendar days after the request was made.
- A customs broker receives reasonable notice of a site visit. The notice includes a request to inspect records pertaining to a client of the brokerage. During the site visit, the broker informs DHS that the records are kept off-site and will not be available for inspection during the visit. The broker states that they will send the records electronically within 30 calendar days of the visit.
- A customs broker receives a request to inspect a customs broker’s records relating to an unused merchandise drawback claim. The request specifies that the broker has up to 120 calendar days to provide the requested records. On the 45th calendar day from the request, the broker sends the original electronic version of the requested records to DHS.
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CBP's answer: D. D: A customs broker receives a request to inspect a customs broker’s records relating to an unused merchandise drawback claim. The request specifies that the broker has up to 120 calendar days to provide the requested records. On the 45th calendar day from the request, the broker sends the original electronic version of the requested records to DHS.
On a DHS request to examine records, the broker must make all records available within 30 calendar days, or such longer time as DHS specifies (111.25(b)). In D, DHS allowed up to 120 days and the broker produced the records on day 45, so D complies. In B the 60 days exceeded the 30-day default, in C the broker refused the site visit inspection and offered records later, and in A the broker still has the records, and 111.25(a) keeps them open to inspection for as long as they remain in the broker's possession.
must make all records available to DHS within thirty (30) calendar days, or such longer time as specified by DHS, at the location specified by DHS 19 CFR 111.25(b)
Search for: within thirty (30) calendar days, or such longer time as specified by DHS
CBP's key cites: 19 CFR 111.23(a); 19 CFR 111.25(a); 19 CFR Part 163
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).