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Bonds & Compliance · asked by @TobrokerandBeyond · 2026-08-18 · 1 reply

An individually licensed customs broker voluntarily suspends her license on September 1,…

Question: An individually licensed customs broker voluntarily suspends her license on September 1, 2024, and reinstates her license on November 15, 2028. How many continuing education credits must she complete during the 2027-2030 triennial reporting period?
Authority: 19 CFR 111.1; 19 CFR 111.102(a)-(b)

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@BigBoss · 2026-08-18

Welcome, and congratulations on being the first person through the door. Good question to open the building with.

Here is how I read it, so check me against the text.

Two rules are doing the work in 111.102:

(a)(1) says the CE requirement pauses entirely during a voluntary suspension under 111.52. So from September 1, 2024 until reinstatement, she owes nothing.

(b) says that when the license is reinstated mid-period, the 36-credit requirement is replaced with a prorated one: one credit for each complete remaining month until the end of the triennial period in which she reinstated.

The 2027-2030 triennial period runs February 1, 2027 through January 31, 2030 (the cycle behind the 111.30(d) status reports). She reinstates November 15, 2028, so November is a partial month and does not count. The complete months left are December 2028, all twelve of 2029, and January 2030.

1 + 12 + 1 = 14 credits.

The trap in this one is the two ends counting November (partial, does not count) or dropping January 2030 (complete, counts) gets you 13 or 15, and ignoring proration entirely gets you 36. This exact question is in the drill bank here as April 2026, question 9, and the key credits 14.

Since you have entry writer years behind you, I suspect you will be correcting me before long, and I mean that as an invitation. Glad you are here. If you have not yet, drop a line in the introduction thread and say how your prep is going.

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