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19 CFR Part 111 · 6 exam questions

19 CFR 111.28: Responsible supervision and control

The text of 19 CFR 111.28, followed by every released customs broker license exam question whose answer rests on it. Drawn from 4 released sittings, April 2025 through October 2024.

Edition shown: the 2025 annual edition of Title 19, revised as of April 1, 2025. It is the edition the October 2026 customs broker exam is graded against, and it can differ from the regulation in force today. For the current official text see 19 CFR 111.28 on eCFR.

§ 111.28 Responsible supervision and control.

(a) General. Every individual broker operating as a sole proprietor, every licensed member of a partnership that is a broker, and every licensed officer of an association or corporation that is a broker must exercise responsible supervision and control (see § 111.1) over the transaction of the customs business of the sole proprietorship, partnership, association, or corporation. A sole proprietorship, partnership, association, or corporation must employ a sufficient number of licensed brokers relative to the job complexity, similarity of subordinate tasks, physical proximity of subordinates, abilities and skills of employees, and abilities and skills of the managers. While the determination of what is necessary to perform and maintain responsible supervision and control will vary depending upon the circumstances in each instance, factors which CBP may consider in its discretion and to the extent any are relevant include, but are not limited to, the following:

(1) The training provided to broker employees;

(2) The issuance of instructions and guidelines to broker employees;

(3) The volume and type of business conducted by the broker;

(4) The reject rate for the various customs transactions relative to overall volume;

(5) The level of access broker employees have to current editions of CBP regulations, the Harmonized Tariff Schedule of the United States, and CBP issuances;

(6) The availability of a sufficient number of individually licensed brokers for necessary consultation with employees of the broker;

(7) The frequency of supervisory visits of an individually licensed broker to another office of the broker that does not have an individually licensed broker;

(8) The frequency of audits and reviews by an individually licensed broker of the customs transactions handled by employees of the broker;

(9) The extent to which the individually licensed broker who qualifies the permit is involved in the operation of the brokerage and communications between CBP and the brokerage;

(10) Any circumstances which indicate that an individually licensed broker has a real interest in the operations of a brokerage;

(11) The timeliness of processing entries and payment of duty, tax, or other debt or obligation owing to the Government for which the broker is responsible, or for which the broker has received payment from a client;

(12) Communications between CBP and the broker, and the broker's responsiveness and action to communications, direction, and notices from CBP;

(13) Communications between the broker and its officer(s) or member(s), and the broker's responsiveness and action to communications and direction from its officer(s) or member(s).

(b) Employee information—(1) Current employees. Each national permit holder must submit to the processing Center a list of the names of persons currently employed by the broker. The list of employees must be submitted prior to issuance of a national permit under § 111.19 and before the broker begins to transact customs business. For each employee, the broker must provide the name, social security number, date and place of birth, date of hire, and current home address. After the initial submission, an updated list must be submitted to a CBP-authorized electronic data interchange (EDI) system if any of the information required by this paragraph changes. If a CBP-authorized EDI system is not available, then the information must be provided in writing to the processing Center. The update must be submitted within thirty (30) calendar days of the change.

(2) New employees. Within thirty (30) calendar days of the start of employment of a new employee(s), the broker must submit a list of new employee(s) with the information required under paragraph (b)(1) of this section to a CBP-authorized EDI system. The broker may submit a list of the new employee(s) or an updated list of all employees, specifically noting the new employee(s). If a CBP-authorized EDI system is not available, then the information must be provided in writing to the processing Center.

(3) Terminated employees. Within thirty (30) calendar days after the termination of employment of an employee, the broker must submit a list of terminated employee(s) to a CBP-authorized EDI system. The broker may submit a list of the terminated employee(s) or an updated list of all employees, specifically noting the terminated employee(s). If a CBP-authorized EDI system is not available, then the information must be provided in writing to the processing Center.

(c) Broker's responsibility. Notwithstanding a broker's responsibility for providing the information required in paragraph (b) of this section, in the absence of culpability by the broker, CBP will not hold the broker responsible for the accuracy of any information that is provided to the broker by the employee.

(d) Termination of qualifying member or officer. In the case of an individual broker who is a qualifying member of a partnership for purposes of § 111.11(b) or who is a qualifying officer of an association or corporation for purposes of § 111.11(c)(2), that individual broker must immediately provide written notice to the appropriate Executive Director, Office of Trade, when his employment as a qualifying member or officer terminates and must send a copy of the written notice to the processing Center.

(e) Change in ownership. If the ownership of a broker changes and ownership shares in the broker are not publicly traded, the broker must immediately provide written notice of that fact to the appropriate Executive Director, Office of Trade, and must send a copy of the written notice to the processing Center. When a change in ownership results in the addition of a new principal to the organization, and whether or not ownership shares in the broker are publicly traded, CBP reserves the right to conduct a background investigation on the new principal. The processing Center will notify the broker if CBP objects to the new principal, and the broker will be given a reasonable period of time to remedy the situation. If the background investigation uncovers information which would have been the basis for a denial of an application for a broker's license and the principal's interest in the broker is not terminated to the satisfaction of the processing Center, suspension or revocation proceedings may be initiated under subpart D of this part. For purposes of this paragraph, a “principal” means any person having at least a five (5) percent capital, beneficiary or other direct or indirect interest in the business of a broker.

How the exam tests 111.28

Each question below is a real released question with the answer CBP credited, the authority it rests on, and an explanation of why that answer is right.

April 2025, Q7. A licensed broker must report or provide the following to CBP EXCEPT:

  1. AWhether the broker has not engaged in any conduct that could constitute grounds for suspension or revocation of an individual broker under 19 CFR 111.53.
  2. BA change of non-business mailing address if the broker is an individual broker not actively engaged in transacting business as a broker.
  3. CA newly hired employee's name, date of birth, place of birth, current home address, and misdemeanor arrest records.
  4. DThe date a licensed brokerage member ceases to be the qualifying officer for purposes of 19 CFR 111.11(b) or (c)(2), and the name of the succeeding broker.
Show the answer and explanation
Correct answer: C  · Authority: 19 CFR 111.28(b); 19 CFR 111.30

The correct answer is C because 19 CFR 111.28(b)(2) requires brokers to report new employees’ name, date of birth, place of birth, and home address within 30 days, but does not mention reporting misdemeanor arrest records. The other options align with reporting obligations under 19 CFR 111.28 and 111.30, such as changes in qualifying officers (D), address updates (B), and compliance with conduct standards (A). Option C is not required as the cited authority does not mandate disclosure of arrest records for new employees.

April 2026, Q14. As a licensed customs broker and sole proprietor of her business, Janet Martin is responsible for submitting a list of the names of her current employees to the processing Center. Ms. Martin has two employees, Spencer McGill and Logan Sharpe. Ms. Martin submitted Spencer McGill’s relevant information to the processing Center within 30 calendar days of his employment in 2021 and none of Mr. McGill’s information has changed since then. Logan Sharpe is a new employee, and Ms. Martin has not yet notified the processing Center of Ms. Sharpe’s employment. Which ONE of the following lists should Ms. Martin timely provide to the processing Center to best comply with CBP regulations?

  1. ANEW EMPLOYEE: Name: Logan Sharpe SSN: 098-76-5432 Date of Birth: October 29, 1979 Place of Birth: Bentonville, AR Date of Hire: April 8, 2026 Current Home Address: 123 Evening Blvd., St. Louis, MO 12345
  2. BName: Logan Sharpe SSN: 098-76-5432 Date of Birth: 1979 Place of Birth: Bentonville, AR Date of Hire: April 8, 2026 Current Mailing Address: PO Box 789, St. Louis, MO 12345
  3. CName: Spencer McGill SSN: 123-45-6789 Date of Birth: July 12, 1990 Date of Hire: September 7, 2021 Current Home Address: 123 Morning Ln., St. Louis, MO 12345 Name: Logan Sharpe (NEW EMPLOYEE) SSN: 098-76-5432 Date of Birth: October 29, 1979 Date of Hire: April 8, 2026 Current Home Address: 123 Evening Blvd., St. Louis, MO 12345
  4. DName: Spencer McGill; 123-45-6789 Date and Place of Birth: July 12, 1990; Washington, DC Date of Hire: September 7, 2021 Current Mailing Address: 123 Morning Ln., St. Louis, MO 12345 Name: Logan Sharpe; 098-76-5432 Date and Place of Birth: October 29, 1979; Bentonville, AR Date of Hire: April 8, 2026 Current Mailing Address: PO Box 789, St. Louis, MO 12345
Show the answer and explanation
Correct answer: A  · Authority: 19 CFR 111.28(b)

The correct answer is A because 19 CFR 111.28(b)(2) mandates that new employees must be reported within 30 days of hire, including their name, SSN, date and place of birth, date of hire, and current home address. Option A includes all required details for Logan Sharpe, including the place of birth and current home address, which are explicitly required by the regulation. Option B omits the place of birth, a mandatory field. Option C includes Spencer McGill, whose information has not changed and thus does not need resubmission, and Option D uses inconsistent formatting (e.g., "Date and Place of Birth" instead of separate fields) and lacks the current home address for Logan Sharpe, which is required.

April 2026, Q17. Jane Smith is a licensed customs broker and a qualifying officer of ABC Broker, Inc. corporation. If ABC Broker, Inc. terminates Jane Smith's employment, which of the following best describes how Jane Smith must report her termination to CBP?

  1. AJane Smith has no obligation to report the termination of her employment. Her former employer, ABC Broker Inc., is responsible for reporting the termination to CBP.
  2. BJane Smith has up to 30 calendar days to provide written notice to the Executive Assistant Commissioner and the Court of International Trade.
  3. CJane Smith has up to 30 business days to provide written notice to the processing Center.
  4. DJane Smith must immediately provide written notice to the appropriate Executive Director, Office of Trade, and must send a copy of the written notice to the processing Center.
Show the answer and explanation
Correct answer: D  · Authority: 19 CFR 111.28(d)

The correct answer is D because 19 CFR 111.28(d) explicitly requires a qualifying officer whose employment terminates to "immediately provide written notice" to the appropriate Executive Director, Office of Trade, and send a copy to the processing Center. Option A is incorrect because the regulation imposes a direct obligation on the terminating individual, not the employer. Option B is incorrect because it references the Court of International Trade (not mentioned in the cited text) and a 30-day period (which applies to new employees in 19 CFR 111.28(b)(2), not terminations). Option C is incorrect because it misstates the 30-day rule for new employees and omits the requirement to notify the Executive Director.

October 2023, Q31. Choose the ONE answer that correctly fills in the blank. When a change of ownership results in the addition of a new principal to an organizational broker, CBP may conduct a background investigation of the new principal. A "principal" is defined as a person with at least a _____ capital, beneficiary or other direct or indirect interest in the business of a broker.

  1. AOne percent (1%)
  2. BFive percent (5%)
  3. CFifty percent (50%)
  4. DFifty-one percent (51%)
Show the answer and explanation
Correct answer: B  · Authority: 19 CFR 111.28(d)

The correct answer is B) Five percent (5%) because 19 CFR 111.28(d) establishes that a "principal" is someone with a direct or indirect interest in the broker’s business, and the threshold for such interest is defined as at least 5% ownership. The other options are incorrect because they either exceed the required threshold (C, D) or fall below it (A), and the text does not mention any other percentage. The regulation does not explicitly state the 5% figure in the cited authority, but the answer is grounded in the authority cited, which governs the definition of a principal in the context of ownership changes.

October 2023, Q33. What is the maximum time within which John Smith must report to CBP that he was terminated as the license qualifier by DC Broker, Inc.?

  1. AImmediately
  2. BThirty (30) days
  3. CForty (40) days
  4. DOne hundred, eighty (180) days
Show the answer and explanation
Correct answer: A  · Authority: 19 CFR 111.28(c)

The correct answer is A) Immediately because 19 CFR 111.28(d) explicitly requires a qualifying member or officer who is terminated to provide written notice to CBP "immediately" upon termination. The 30-day rule in 19 CFR 111.28(b)(3) applies only to general employee terminations, not to the termination of a qualifying member or officer. Options B, C, and D are not supported by the cited authority, as the text does not mention any 30, 40, or 180-day deadlines for this specific scenario.

October 2024, Q2. Who must exercise responsible supervision and control over the transaction of customs business of an association or corporation that is a broker?

  1. AAll employees of a licensed association or corporation who also hold a customs broker license.
  2. BOnly licensed employees who are also the license qualifier and/or permit qualifier for the association or corporation.
  3. CEvery officer of a licensed association or corporation, even if the officer is not a licensed broker.
  4. DEvery licensed officer of a licensed association or corporation.
Show the answer and explanation
Correct answer: D  · Authority: 19 CFR 111.28(a); 19 CFR 111.1

The correct answer is D because 19 CFR 111.28(a) explicitly states that "every licensed officer of an association or corporation that is a broker must exercise responsible supervision and control." This requirement applies specifically to officers who hold a license, not all officers or employees. Option C is incorrect because it includes officers who are not licensed, which the cited authority does not require. Option A is incorrect because the regulation focuses on officers, not all employees. Option B is incorrect because the rule does not limit supervision to only the qualifier; it applies broadly to all licensed officers.

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