Customs Broker Regulations, Licensing, and Broker Responsibilities (19 CFR Part 111)
Part 111 controls who may transact customs business for others and how that business is conducted. A candidate must know the difference between the individual broker license (earned through CBP's written examination and application process, with a passing score of 75%) and the permit that authorizes practice at a port or nationally. A corporation or partnership needs a broker license too, and must designate a licensed individual as the qualifying/designated broker responsible for supervision.
Core duties include responsible supervision and control over employees and offices, confidentiality, loyalty, and proper use of a power of attorney from each client. Brokers must keep records of customs business for five years; the period generally runs from the date of entry or from the date of the activity that required the record, whichever is later. Do not confuse a license with a permit: a license without a permit does not authorize practice, and a permit can be revoked or suspended separately.
Question traps: (1) treating the broker exam as the only requirement, ignoring the permit; (2) assuming a corporate license qualifies every employee; (3) misstating the record-retention period as three or seven years; (4) forgetting that a broker may not represent conflicting parties without disclosure/consent; and (5) confusing "customs business" with purely clerical or transportation services.
Worked example/rule of thumb: A broker files an entry on January 10 and later files a post-entry claim on March 1 two years later. Retain the entry records at least five years from January 10, and retain the claim-related records at least five years from the later activity date. Rule of thumb: license = person; permit = place/practice; five years = records.