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October 2026, question 19
Practical Exercise · Liquidation, reliquidation and protests
Freight forwarder Ms. Dowd had executed the following POA with General Merchants before she referred them to Broker A for the transaction of their customs business. Which ONE of the following statements is TRUE regarding actions Ms. Dowd may take? POWER OF ATTORNEY GENERAL MERCHANTS CORP. hereby authorizes MARIA DOWD (Grantee) as its true and lawful agent and attorney-in-fact for the limited purpose of issuing shipping instructions and communications, filing protests, arranging transportation, forwarding, storage, and related logistics services for cargo imported to or exported from the United States from March 21, 2022 onwards. This agreement does not authorize Grantee to transact customs business as defined under 19 CFR Part 111 unless Grantee is duly licensed as a United States Customs Broker and separately authorized for such purpose. Signed: Thomas P. Willyard Capacity: VICE PRESIDENT of GENERAL MERCHANTS CORP. Date: MARCH 21, 2022
- Ms. Dowd upon request from General Merchants can file a protest as an authorized agent of General Merchants provided that she attaches this POA to the protest she files.
- Ms. Dowd upon request from General Merchants to file a protest must refer this to Broker A as filing a protest constitutes conducting customs business.
- Ms. Dowd may file entries on behalf of General Merchants as an authorized subagent of Broker A.
- Ms. Dowd upon request from General Merchants can file a protest as an attorney at law.
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CBP's answer: A. A: Ms. Dowd upon request from General Merchants can file a protest as an authorized agent of General Merchants provided that she attaches this POA to the protest she files.
A protest filed by an agent who is not an attorney at law or a customhouse broker must be accompanied by a power of attorney that specifically authorizes the agent to make, sign and file the protest, or grants unlimited authority (174.3(a)). Ms. Dowd's power of attorney expressly covers filing protests, so she may file one if she attaches it, and A is right. Filing a protest by an authorized agent is not by itself customs business she must hand to a broker, she is not an attorney at law, and the power of attorney bars her from entering merchandise.
there shall have been filed or shall be filed with the protest a power of attorney which either specifically authorizes such agent to make, sign, and file the protest or grants unlimited authority to such agent 19 CFR 174.3(a)
Search for: Power of attorney to file protest
CBP's key cites: 19 CFR 141.42; 19 CFR 111.37
Question and key from CBP's October 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).