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The submission supports 40 hours over a 3-year period as appropriate and recommends the requirement cover continuing updates on both import and export of goods. It describes qualifying education formats, including CBP and government-agency webinars, industry and professional-association events, conferences, and training by firms and government bureaus. It also proposes a certification process within CBP to validate training content and applicability.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":20,"@type":76,"position":81},"https://docshare.wps.com/document/exam/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/continuing-education-for-licensed-customs-brokers-rin-1651-ab03/395953/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/continuing-education-for-licensed-customs-brokers-rin-1651-ab03/395953.png","ImageObject",300,407,{"name":92,"@type":93},"Anna Hans","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-01","2026-09-26",true,{"@type":102,"interactionType":103,"userInteractionCount":44},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What continuing education duration does the submission recommend for licensed customs brokers?","Question",{"text":112,"@type":113},"It recommends 40 hours over a 3-year period. The submission argues this is commensurate with other professional licensure requirements.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"Which types of activities should count toward continuing education under the proposed framework?",{"text":117,"@type":113},"It should include training offered by CBP and other government agencies, educational webinars, professional-association events, conferences, professional services training, and relevant classes from U.S. government bureaus addressing international trade topics.",{"name":119,"@type":110,"acceptedAnswer":120},"How should training be validated to ensure it qualifies as continuing education?",{"text":121,"@type":113},"The submission proposes a certifying process and a group within CBP to certify training content and applicability, maintaining certification standards.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},395953,1790555153,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":19,"category_name":20,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":44,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":139,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},5909892332657,"https://ap-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","December 28, 2020  \nComments submitted via the Federal eRulemaking Portal: [http://www.regulations.gov](http://www.regulations.gov)  \n[Elena D. Ryan](Elena D. Ryan)  \nSpecial Advisor, Programs and Policy Analysis Trade and Commercial Regulations Branch Regulations and Rulings, Office of Trade  \nU. S. Customs and Border Protection  \n90 K Street NE (10th Floor) Washington, DC 20229-1177  \nSubject: Continuing Education for Licensed Customs Brokers  \nReference: RIN 1651-AB03 – Federal Register / Vol. 85, No. 209 / Wednesday, October 28, 2020 / Advanced Notice of Proposed Rulemaking (ANPRM)  \nDear Ms. Ryan:  \nThe Computing Technology Industry Association (CompTIA), the leading association for the global information technology (IT) industry, thanks you for your time in reviewing our responses to the ANPRM on continuing education for licensed customs brokers. Many CompTIA members employ licensed customs brokers within their corporate global trade or customs compliance function. We agree that requiring customs brokers to fulfill a continuing education requirement will augment keeping up with evolving customs practices as well as new regulations and rulings issued by U.S. Customs and Border Protection (CBP) and Partner Government Agencies (PGAs) . In addition, we believe the continuing education requirement will enhance the credibility and value of a customs broker license.  \nGeneral Comments  \nDue to the significance of this potential new requirement which will affect the 10,000+ licensed brokers, and the length and complexity of this ANPRM including the number of questions asked, we strongly recommend that a Notice of Proposed Rulemaking (NPRM) be issued for additional comments before the rule is issued in final form.  \nIII. Discussion of a Potential Framework for Continuing Education for Licensed Customs Brokers  \nA. How many hours of continuing education would be required?  \nQuestion 1. Is 40 hours over 3 years an appropriate level of continuing education directly related to the import and export of goods into and out of the United States? Why or why not? If you disagree, please indicate in your answer what would be a preferred level and your rationale.  \nAnswer: CompTIA is ofthe view that 40 hours over a 3-year period is commensurate with other professional licensure requirements. We would also propose the continuing education address both the import and export of goods into and out of the United States.  \nB. What types of activities should be considered appropriate to qualify as continuing education?  \nQuestion 2. In addition to the opportunities offered by CBP and other government agencies as mentioned above, are you aware of other training or coursework that would likely qualify for a continuing education requirement? Please describe those opportunities in detail.  \nAnswer: CompTIA has a longstanding partnership with the U.S. Customs and Border Protection Electronics Center of Excellence and Expertise. During the past 3 years, we have developed and facilitated bidirectional education webinars on Section 301 Duties; Current Use of Emerging Technologies in Work Flows to Support Compliance, Efficiency, Facilitation & Enforcement; E-Commerce; Virtual Reality and Customs Classification;  \nBlockchain in the Supply Chain and Across Industry and Government; Section 301 Exclusions; Forced Labor Importer Due Diligence; and CTPAT and CTPAT Trade Compliance. Speakers participating in these 60-90 minute educational webinars have included industry experts, U.S. Customs and Border Protection officials, as well as senior officials from PGAs. We believe these trainings should qualify for the continuing education requirement.  \nIn addition, professional associations such as OWIT Northern California1 convene monthly events which feature industry experts and government officials providing an educational presentation on a current compliance related topic. For example, in October 2020, they partnered with the Customs Brokers and Forwarders Associati","cbCaifk59MgF6tDs","https://ap.wps.com/l/cbCaifk59MgF6tDs","pdf",158261,13,"English","# General Comments\n# Discussion of a Potential Framework for Continuing Education for Licensed Customs Brokers\n## How many hours of continuing education would be required?\n## What types of activities should be considered appropriate to qualify as continuing education?\n## Are there company or brokerage training materials that should qualify?","[{\"question\":\"What continuing education duration does the submission recommend for licensed customs brokers?\",\"answer\":\"It recommends 40 hours over a 3-year period. The submission argues this is commensurate with other professional licensure requirements.\"},{\"question\":\"Which types of activities should count toward continuing education under the proposed framework?\",\"answer\":\"It should include training offered by CBP and other government agencies, educational webinars, professional-association events, conferences, professional services training, and relevant classes from U.S. government bureaus addressing international trade topics.\"},{\"question\":\"How should training be validated to ensure it qualifies as continuing education?\",\"answer\":\"The submission proposes a certifying process and a group within CBP to certify training content and applicability, maintaining certification standards.\"}]","Continuing Education for Licensed Customs Brokers - RIN 1651-AB03 | PDF",1790426462,33]