19 CFR Part 111 — Customs Brokers

April 2023, Q67. How long after attaining a passing grade on the Customs Broker License Exam (CBLE) does an applicant have to apply for a Customs broker license?

1. AThree (3) months
2. BOne (1) year
3. CTwo (2) years
4. DThree (3) years
5. EFive (5) years

April 2023, Q68. Which of the following dates is the earliest date that an examinee who took the Customs Broker License Exam (CBLE) on October 26, 2022, is eligible to apply for a customs broker license under the following facts? The examinee's birth date is October 12, 2004. The examinee was notified that the examinee passed the CBLE on November 10, 2022. The examinee received the applicati on instruction letter from the processing Center on December 1, 2022.

1. AOctober 27, 2022
2. BNovember 10, 2022
3. CDecember 1, 2022
4. DOctober 12, 2025
5. EOctober 26, 2025

April 2023, Q69. Within how many working days must a licensed customs broker transmit a payment to CBP of funds received from an importer after the payment due date?

1. AOne (1)
2. BTwo (2)
3. CThree (3)
4. DFive (5)
5. ETen (10)

April 2025, Q1. A customs broker has a client's confidential records as defined in CBP regulations pertaining to customs brokers. The records contain information that is not available from a source that is open to the public. The broker's client has specified in writing that the records should be kept confidential. Of those persons listed below, to whom may the broker disclose the confidential records?

1. AThe client's surety on a particular entry
2. BThe freight forwarder on a particular shipment
3. CThe broker's other clients
4. DThe client's exporter

April 2025, Q5. Which of the following would NOT constitute grounds sufficient to deny an application for a customs broker’s license?

1. AAny conduct which would be deemed unfair or detrimental in commercial transactions by accepted standards.
2. BA failure to establish the good character and reputation of the applicant.
3. CBeing 20 years old on the date of submission of the broker's license application.
4. DBeing a citizen of the United States for only one year prior to the date of submission of the broker’s license application.

April 2025, Q8. In accordance with the relevant regulation in Part 111 of 19 CFR, if a customs broker discovers a breach of electronic or physical records relating to the broker’s customs business, the broker must electronically notify _____ within 72 hours of the discovery of the breach.

1. ABroker Management Branch, Office of Trade, CBP Headquarters
2. BBroker Management Officer at the processing Center
3. CThe appropriate Executive Director, Office of Trade, CBP Headquarters
4. DCBP Office of Information, Technology Security Operations Center (CBP SOC)

April 2025, Q12. A customs broker receives payment for duties from a client after the due date. The payment did not include payment for the broker's services. What must the broker do?

1. AReturn the payment to the client within 5 working days of receipt and file a formal complaint with CBP.
2. BAdvise the client that the duty payment will not be transmitted to CBP until the payment for the broker's services is received.
3. CTransmit the duty payment to CBP within 5 working days of receipt by the broker.
4. DDeduct their service fee from the amount of the payment, transmit the remaining amount to CBP, and notify the center director of the situation.

April 2025, Q15. A freight forwarder is referring an import client to a customs broker with an expectation of receiving a referral fee. Which ONE of the following statements is legally TRUE with respect to their relationship?

1. AThe customs broker may execute a customs power of attorney with the importer via the freight forwarder, via another third party, or with the importer directly to transact customs business for that importer.
2. BThe importer must be notified in advance by the freight forwarder or broker of the name of the broker with whom the freight forwarder is doing business for the handling of the importer’s Customs transactions.
3. CThe agreement between the freight forwarder and the customs broker may stipulate that the importer may only communicate with the broker through the freight forwarder.
4. DThe broker and freight forwarder may not enter into an agreement such that the freight forwarder, as an unlicensed person, benefits from the broker’s services rendered to and fees earned from the importer.

April 2026, Q2. Which ONE of the following activities may qualify for one credit of continuing broker education?

1. AViewing a one-hour recording of a CBP webinar offered to prepare registered CBLE examinees for exam-day procedures.
2. BAttending a one-hour discussion session on the potential use of artificial intelligence in tariff classification. The session is offered during an in-person trade workshop near the Port of Baltimore and is attended by several CBP employees. The discussion leader has stated that the event organizers intend to seek approval for continuing broker education credit for the discussion session after the session concludes.
3. CGiving a one-hour lecture on duty refund opportunities for educational institutions at a convention for educators and university procurement officers. The lecture and the convention have been approved for continuing broker education credit by a CBP-selected accreditor, prior to being held.
4. DOne hour spent preparing subject matter for a self-guided, five-month long online course on valuation that commenced at the start of the year. The course culminates in a retention test and has been approved for continuing broker education credit by a CBP-selected accreditor.

April 2026, Q6. 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.

1. AA 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.
2. BA 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.
3. CA 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.
4. DA 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.

April 2026, Q10. A customs broker discovers that a client has omitted information from an affidavit. The broker believes the client omitted the information by mistake and advises the client promptly of the omission and the proper corrective actions required. What else must the broker do?

1. AProvide the client with the monetary penalty associated with making the omission.
2. BTell the client the broker can no longer conduct customs transactions on the client's behalf.
3. CRetain a record of their communication with the client.
4. DSuspend their customs broker's license until the client resolves their omission on the affidavit.

April 2026, Q11. Of the four choices below, which business relationship may Tracy, a licensed customs broker and sole proprietor of her brokerage, maintain without violating CBP regulations?

1. ATracy transacts customs business on behalf of her client, X-Logistics, a bona fide importer. At the time when she entered into the broker-client relationship, Tracy knew that X-Logistics was a notoriously disreputable importer.
2. BTracy has an agreement with Faith, another sole proprietor who had her customs broker license suspended with prejudice. For the duration of Faith’s license suspension, Faith refers her clients to Tracy, and Tracy gives Faith a small percentage of the fees collected from the clients Faith referred to her.
3. CTracy befriends an attorney, Margaret, at a trade conference. Margaret works for the Office of Regulations and Rulings at the Department of Homeland Security and authors classification rulings for the type of widgets that Tracy’s clients import. Tracy treats Margaret to a nice dinner in exchange for the opportunity to talk about the classification rulings pending Margaret’s review.
4. DTracy hires Paul to help with recordkeeping at her brokerage. Six months after Paul’s start date, Tracy discovers that Paul is a convicted felon. Tracy takes no futher action and continues to employ Paul.

April 2026, Q12. Which of the following statements regarding national permits is FALSE?

1. AA national permit is required for the purpose of transacting customs business throughout the customs territory of the United States.
2. BIndividuals who obtain a passing grade on the Customs Broker License Examination may submit applications for a customs broker license and a national permit at the same time.
3. CApplicants who receive notification from the appropriate Executive Director, Office of Trade, CBP Headquarters that their national permit application has been denied may appeal the decision to the Court of International Trade directly, provided that the appeal action is commenced within 60 calendar days after the original denial date by the Executive Director.
4. DThe individual broker who qualifies their business entity for a national permit is required to exercise responsible supervision and control over the activities conducted under that national permit.

April 2026, Q16. In the event of a cyberbreach of electronic records relating to customs business, when must the customs broker report the breach to CBP following the discovery of the breach?

1. AWithin 72 hours
2. BWithin 10 calendar days
3. CWithin 10 business days
4. DWithin 30 calendar days

May 2024, Q1. Which of the following statements is FALSE?

1. AOnly customs brokers who have been approved for a National Permit are required to pay the annual user fee every year.
2. BAll customs brokers are required to file the triennial status report and pay the associated fee every three years after 1985.
3. CEvery applicant for a customs broker's license must pay an application fee, the amount of which is based upon whether the applicant is an individual, a partnership, an association, or a corporation.
4. DAll customs brokers are required to file an annual status report and pay the annual user fee every year after 1985.

May 2024, Q7. A customs broker license applicant has been denied a customs broker license. Which of the following best describes the next action the applicant must take to initiate an appeal?

1. AFile with the Executive Assistant Commissioner, Office of Trade, in writing, a request for additional review that the Executive Assistant Commissioner deems appropriate not later than ninety (90) days of the denial.
2. BFile with the appropriate Executive Director, Office of Trade, in writing, additional information or arguments in support of the application. Such information and arguments must be received by the Executive Director within sixty (60) calendar days of the denial.
3. CAppeal the decision to the Court of International Trade within thirty (30) days of the denial.
4. DAppeal the decision by filing a written or electronic appeal with the Office of Trade, CBP Headquarters within thirty (30) days of the denial.

May 2024, Q8. Which of the following scenarios demonstrates that a customs broker may have failed to maintain responsible supervision and control over their customs business?

1. AJohn Smith Customs Brokerage (Smith) terminated Sally Johnson's (Johnson) employment. Johnson was listed in Smith's Automated Commercial Environment (ACE) portal account as the knowledgeable point of contact to be available to CBP during and outside of normal operating hours. Smith updated Johnson's employee record but did not designate a new knowledgeable point of contact in ACE. CBP has been unable to contact Smith for over six months.
2. BCountrywide Customs Brokerage (Countrywide) has ten offices across the United States under a National Permit with an approved supervision plan. Two of these offices do not have a licensed broker on site and have not had one for six months. Although Countrywide has not requested a waiver, Countrywide has a licensed broker conduct a supervisory visit twice a week to those offices.
3. CNational Customs Brokerage (National) unwittingly hired James Jones, Sr., a convicted felon who committed embezzlement ten (10) years ago. On his employment application, Jones stated that he did not have any felony convictions and used another person's social security number. National did not seek a waiver to employ a convicted felon.
4. DTrustworthy Customs Broker Co. (Trustworthy) received $10,000.00 from Sally Doe, an importer of handblown glass figurines. Sally has designated Trustworthy to make payment for all imports over the course of a year, and to collect any refunds issued by CBP. Sally owes $4,000.00 in estimated duties for her most recent acquisition of figurines. Trustworthy remitted payment to CBP within 12 days of the figurines’ arrival at the Port of Long Beach.

May 2024, Q10. Which of the following statements is TRUE? For the purposes of this question, an organization means a partnership, association, or corporation.

1. AAn applicant for a national permit applying on behalf of an organization must be an individually licensed customs broker employed by the organization and such individual will also be responsible for exercising responsible supervision and control over the activities conducted under that national permit.
2. BAn applicant who obtains a passing grade on the examination for an individual broker license may apply for a national permit and the permit will be issued if the broker license is denied as long as the requirements of 19 CFR 111.19(b)(2) - (11), (c) and (d) are met.
3. CAn organizational broker must be issued a district permit by the processing Center before the organization may apply for a national permit for the purpose of transacting customs business in accordance with the requirements in 19 CFR Part 111.
4. DAn employee of a broker may, acting on his or her own behalf and without an individual license, while on the employer's premises, execute powers of attorney between the employee and clients of the employee and use the employer's facilities to conduct customs business on behalf of those clients.

May 2024, Q11. Pursuant to CBP regulations regarding CBP's Office of Information Technology Security (CBP SOC), what must a broker do when there is a breach of physical records related to the broker's customs business?

1. ANotify electronically the CBP Office of Information Technology Security Operations Center (CBP SOC) within 72 hours of the discovery and provide CBP SOC with any known compromised importer identification numbers.
2. BNotify electronically and by mail CBP SOC within 72 hours of the discovery and provide CBP SOC any known compromised importer identification numbers.
3. CNotify the broker's assigned processing Center within 72 hours of the discovery and let their clients know their operations are temporarily suspended.
4. DNotify the CBP Executive Assistant Commissioner within ten (10) days of the discovery and provide any known compromised importer identification numbers.

May 2024, Q12. Which of the following statements is FALSE?

1. AA broker must transmit payment to the Government within five (5) working days after receipt from a client if the due date has passed.
2. BRecords pertaining to the business of the clients serviced by customs brokers are to be considered confidential.
3. CWithout exception, a broker who imports merchandise must not act as a broker for an importer who imports merchandise of the same general character as that imported by the broker.
4. DEach broker must exercise responsible supervision and control over the transaction of customs business.

May 2024, Q18. Baltimore Quick Printers is an active client of Fast Broker LLC with a power of attorney executed on May 1, 2020. Please refer to the provided broker's invoice for the "NOTICE TO CLIENT OF METHOD OF PAYMENT" (Notice) language. If the invoice did not contain this Notice, which of the statement(s) is/are correct regarding the broker's obligation to provide active clients this language? I. The notice is not required by Customs regulations. II. The notice is required on every broker invoice to active clients under the Customs regulations. III. The notice is required on or attached to the power of attorney between the broker and the client under the Customs regulations. IV. The notice is required in writing at least once per 12-month period under the Customs regulations.

1. AI.
2. BII.
3. CII. And IV.
4. DIII. And IV

October 2023, Q28. Which ONE of the following is NOT included in 19 CFR 111.91(a) as grounds for the imposition of a monetary penalty?

1. AA person who is not a broker has transacted Customs business without a license.
2. BA licensed broker who, in the course of Customs business, with intent to defraud, has deceived, misled or threatened any client or prospective client.
3. CA licensed broker who has knowingly aided or abetted the violations by any other person of any provision of any law enforced by Customs.
4. DA licensed broker who supplied false or misleading material information on the application for a Customs broker's license.

October 2023, Q32. To avoid having its license and permit revoked by operation of law, what is the maximum time within which DC Broker, Inc. must replace the officer who qualified the license under 19 CFR 111.11(c)(2) from the date the officer was terminated from employment?

1. AImmediately
2. BThirty (30) days
3. COne hundred, twenty (120) days
4. DOne hundred, eighty (180) days

October 2023, Q34. Which of the following is a violation of 19 CFR 111.41? A non-resident importer has executed a Special Address Notification per 19 CFR 24.36 authorizing the mailing of refunds, bills, or notices of liquidation to its broker.

1. AThe broker accepts a paper check refund from CBP which is made payable to the importer and mails the check to the non-resident importer.
2. BThe broker files a drawback entry on behalf of the importer. Subsequently, CBP electronically transfers the drawback refund directly to the importer’s U.S. bank account.
3. CThe broker files a post-summary correction (PSC) for a refund. Subsequently, CBP mails the broker a paper check payable to the importer. The broker endorses the check, deposits it into its account, and re-invoices the importer for the lesser amount of duties, taxes, and fees.
4. DThe broker files an entry and pays the duties, taxes, and fees on behalf of the importer. CBP liquidates the entry with a rate advance and the broker receives the bill. Without consulting with the importer, the broker pays the bill and invoices the importer for the amount the broker paid to CBP.

October 2024, Q3. While preparing the entry documents for a shipment on behalf of its client Angel Industries (Angel), Shady CHB (Shady) sees that the insurance value for the shipment is significantly lower than the commercial invoice value. In response to Shady's inquiry concerning the differences, Angel explains that there are two commercial invoices for the shipment. The first commercial invoice is the real invoice from the shipper which shows the lower amount that is used for insurance purposes. The second commercial invoice is created by Angel at a higher amount and is used as the invoice for calculating Customs value and upon which it pays the duties, taxes, and fees. Angel explains that it uses the two invoice system in its accounting records to reduce its reportable profit for income tax purposes. Shady's attorney advises Shady to terminate its relationship with Angel because the “double invoice scheme” is fraudulent. Of the choices below, what is Shady's best next step?

1. AShady documents the double invoice scheme and immediately terminates its relationship with Angel and reports to CBP the client's name, date of termination, and the reason for the termination.
2. BShady will file the entry using the lower, correct value and will advise Angel that they will only file entry in the future using the actual invoice from the shipper.
3. CShady will file the entry at the value requested by Angel and will keep Angel as a client because the potential fraud does not involve CBP.
4. DShady will file the entry as requested by Angel because it is not fraud to pay more in duties, taxes, and fees than actually owed.

October 2024, Q5. ____ must be set forth in or attached to an application for a new national permit to describe how responsible supervision and control will be exercised over the customs business conducted under the national permit.

1. AA supervision plan
2. BA regulation proposal
3. CA status report
4. DA control strategy

October 2024, Q6. What is the maximum number of calendar days that the designated recordkeeping contact has to make the records available to CBP, if the request does NOT specify additional time to respond?

1. A10
2. B15
3. C30
4. D60

October 2024, Q16. Which of the following statements is FALSE with respect to the Power of Attorney (POA)?

1. AThe language in the POA confirming that Echo’s agent is: 1) a resident; and 2) authorized to accept service of process against Echo means that the POA can be accepted by CBP pursuant to 19 CFR 141.36.
2. BThe POA must also have attached documentation establishing the authority of Joan McKay to execute the POA on behalf of Echo pursuant to 19 CFR 141.37.
3. CThe written notification set forth in 19 CFR 111.29(b)(1) must be on, or attached to, the POA pursuant to 111.29(b)(2)(i).
4. DThe POA must contain a corporate seal of the grantor as specified in 19 CFR 113.37(g)(1)(v).

October 2025, Q1. Which ONE of the following constitutes an impermissible "misuse of license or permit" pursuant to CBP regulations pertaining to licensed customs brokers?

1. AA broker allows an unlicensed person, who is not an employee, to solicit, promote or perform any customs business or transaction using the broker's license.
2. BA broker influences or attempts to influence the conduct of any representative of the Department of Homeland Security in any pending matter by the use of duress or false accusation.
3. CA broker procures or attempts to procure information from Government records to which they have not been granted access by proper authority.
4. DA broker knowingly uses false or misleading representations to procure employment pertaining to a customs matter.

October 2025, Q2. AA Customs Brokers, Inc. has a corporate customs broker license and a national permit. Tom, the individually licensed broker who was the corporation's national permit qualifier, has recently resigned from AA Customs Brokers, Inc. What is the maximum number of days from Tom's effective resignation date that AA Customs Brokers, Inc. has to find a new licensed customs broker to qualify its national permit to avoid their permit's revocation by operation of law?

1. A120 days
2. B60 days
3. C30 days
4. D180 days

October 2025, Q5. Which ONE of the following is NOT required to be maintained by a broker as evidence of their registration for, attendance at, or completion of the qualifying continuing broker education?

1. AThe location where the broker completed the qualifying continuing broker education.
2. BThe name of the entity or person who provided the qualifying continuing broker education.
3. CThe date(s) the broker attended the qualifying continuing broker education.
4. DThe date(s) the broker received proof of completing the qualifying continuing broker education.

October 2025, Q6. Which people and/or entities must certify completion of the continuing broker education requirement with their status report required under 19 CFR 111.30(d)? i. Individually licensed brokers; ii. Partnerships with customs broker licenses; iii. Associations with customs broker licenses; iv. Corporations with customs broker licenses

1. Ai
2. Bi and ii
3. Cii, iii, and iv
4. Di, ii, iii, and iv

October 2025, Q7. 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. AZX 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. BZX 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. CZX 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. DPrior 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.

October 2025, Q8. Suzy Smith is a licensed customs broker, and her license is overseen by the Processing Center located in Miami, Florida. Ms. Smith seeks to obtain a national permit in her individual capacity to transact customs business throughout the customs territory of the United States. Ms. Smith's application included the following information: (1) the applicant's broker license number and date of issuance; (2) the address, telephone number, and email address of the office designated by the applicant as the office of record; (3) the name, telephone number, and email address of the point of contact to be available to CBP to respond to issues related to the transaction of customs business; (4) a list of all employees together with the specific employee information prescribed in 19 CFR 111.28 for each employee; (5) the location where records will be retained; (6) the name, telephone number, and email address of the knowledgeable employee responsible for broker-wide records maintenance and financial recordkeeping requirements; (7) and a receipt showing that the fees specified in 19 CFR 111.96(b) and (c) have been paid. What additional materials must Ms. Smith provide to complete her application for a national permit?

1. AA request to move oversight of her license to CBP Headquarters.
2. BA waiver for the national permit examination.
3. CA supervision plan describing how she will exercise responsible supervision and control over the customs business conducted under the national permit.
4. DA list of her past employers, regardless of whether the employment was related to the transaction of customs business.

October 2025, Q12. When merchandise is withdrawn from a bonded warehouse, records relating to the withdrawal must be retained by a customs broker for how many years from the date of the last withdrawal?

1. A2
2. B4
3. C5
4. D6

October 2025, Q14. 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. AAndrew Balder may not import items similar to that of MCB's clients because it would be a conflict of interest.
2. BAn employee of a broker may not also be an importer.
3. CAndrew Balder must notify the appropriate Center Director and seek permission to import such articles.
4. DAndrew Balder must notify the MCB's client that they are also going to import dual color lapel men’s dress jackets.

October 2025, Q16. An individually licensed broker subject to continuing broker education requirements completed a qualifying course on April 15, 2027. The broker is maintaining appropriate records pertaining to their continuing education in accordance with applicable CBP regulations. The broker certified completion of their continuing education hours with the filing of their triennial status report on February 1, 2030. For how long is the broker required to maintain a record of their April 15, 2027, continuing education course - which of the following dates identifies the right timeframe?

1. AApril 15, 2030
2. BFebruary 1, 2033
3. CApril 15, 2033
4. DFebruary 1, 2035

October 2025, Q17. Which answer choice correctly completes the following statement: Upon CBP's request, the individual broker must make available to CBP the information and documentation pertaining to the qualifying continuing broker education completed during a triennial period on or before _____.

1. A30 calendar days from the date of CBP's request
2. B30 business days from the date of CBP's request
3. C30 calendar days from the date of receipt of CBP's request
4. D30 business days from the date of receipt of CBP's request

October 2025, Q18. At the conclusion of the 2024-to-2027 triennial reporting period, Joe Slacker, a licensed customs broker and part-time college student, completed eight hours of accredited continuing broker education and two semesters of supply chain management college coursework. As a customs broker he was required to complete 20 hours of qualifying continuing broker education. Mr. Slacker submitted a triennial status report, but he failed to report or certify compliance with the continuing broker education requirement. What must Mr. Slacker do to rectify his non-compliance and maintain his license?

1. ASubmit a corrected status report certifying the eight continuing broker education hours completed during the triennial period within 30 calendar days of the issuance of CBP's notice of failure to report and certify compliance.
2. BRequest a waiver under 19 CFR 111 from completing the remaining 12 qualifying continuing education credit hours as Mr. Slacker completed more than 12 hours of supply chain management coursework at the collect he attended.
3. CComplete the required number of qualifying continuing broker education credits and submit a corrected status report within 30 calendar days of the issuance of CBP's notice of failure to report and certify compliance.
4. DRetake and pass the Customs Broker License Exam within 120 calendar days of CBP's notice of failure to report and certify compliance.

October 2025, Q20. Mr. Jones, a buying agent with power of attorney for importer American Widgets, employs licensed customs broker Ms. Smith for the transaction of customs business and Speedy Freight Forwarder for the transportation of merchandise on behalf of American Widgets. Mr. Jones does not have a customs broker license. American Widgets' imported merchandise was not purchased on a delivered duty-paid basis. Ms. Smith executed a power of attorney directly with American Widgets. Of the following choices, what additional action must Ms. Smith take for billing purposes?

1. AMs. Smith must transmit either a copy of her bill for services rendered or a copy of the entry to American Widgets, unless American Widgets waives transmittal.
2. BMs. Smith must pay a finder's fee to Mr. Jones for the referral of American Widgets' customs business.
3. CMs. Smith must execute a power of attorney directly with Speedy Freight Forwarder.
4. DMs. Smith must transmit directly to Speedy Freight Forwarder a copy of the brokerage charges.