Broker Compliance · CBLE study guide
Broker licensing, permits & status reports
License eligibility and application, national permit, triennial status report, fees, CE.
- 60past questions in CBLE Pass
- ≈5questions on a typical 80-question exam
- 19 CFR 111.11-111.20, 111.30, 111.45, 111.96, 111.101-111.104where the rules live
Common traps
Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.
120 vs. 180 days for organizational qualifiers
“An organization has 120 (or 30/60) days to replace its permit qualifier.”
The rule: Without a licensed member/officer for 120 continuous days, the license and permit are revoked; without a licensed permit qualifier for 180 continuous days, the permit is revoked.
Remember: License qualifier: 120 days. Permit qualifier: 180 days.
19 CFR 111.45(a)
Triennial report vs. annual permit fee
“Every broker files an annual status report and pays an annual user fee.”
The rule: The status report is triennial (every third year, filed in February) with a $100 fee. The annual user fee applies only to holders of a national permit.
Remember: Two clocks: triennial report = every licensed broker; annual user fee = national permit holders only.
19 CFR 111.30(d) · 19 CFR 111.96(c)-(d)
What counts as customs business
“Licensing paperwork, related-company compliance work, or general shipping logistics is customs business.”
The rule: Customs business covers entry and admissibility, classification and valuation, payment of duties and charges, refunds and drawback, and preparing or transmitting documents for filing with CBP for those purposes. Corporate compliance activity and mere data transmission are excluded.
Remember: Ask: is this a transaction with CBP about the goods or the duties?
19 CFR 111.1
License application and exam-appeal timing
“Deadlines run from the exam date or are 6–12 months.”
The rule: Apply within 3 years after passing (111.11(a)(4)); appeal a failing grade within 60 calendar days of the result notice (111.13(f)); apply to the processing Center on CBP Form 3124 (111.12(a)).
Remember: Pass → 3 years; fail → 60 days to appeal.
19 CFR 111.11(a) · 19 CFR 111.13(f) · 19 CFR 111.12(a)
Two ways to authorize an unlicensed employee
“A broker must file the employee's POA with CBP, or prove the employee's age and citizenship.”
The rule: An unlicensed employee may act for the broker if (1) the broker has executed a POA authorizing the employee to sign documents (not filed; shown to CBP on request) or (2) the broker has filed a statement with the processing Center authorizing the employee to transact other business.
Remember: POA to sign = keep it; statement for other business = file it.
19 CFR 111.2(a)(2)(ii)(A)
Reinstating a license suspended for no triennial report
“Reinstatement requires an appeal or a penalty, or has a very short window.”
The rule: File the report and pay the fee within 60 calendar days of the suspension notice; otherwise the license is revoked by operation of law.
Remember: Suspended March 1; 60 days from the notice to cure.
19 CFR 111.30(d)(4)
Try a past question
October 2026 CBLE, question 17
Bob Broker, an individual licensed customs broker, is employed by Fine Furniture, an importer. Fine Furniture makes classification decisions, valuation decisions, prepares entry summaries, and communicates directly with CBP on technical matters. As part of his employment, Bob Broker uses his individual customs broker license, filer code, and national permit to file customs entries for Fine Furniture's imported merchandise. Fine Furniture compensates Bob Broker as a salaried employee. CBP has determined that Fine Furniture is conducting "customs business" without an organizational broker's license, and Bob Broker is allowing his individual broker's license to be used by an unlicensed entity to transact "customs business." This arrangement has been ongoing for 10 separate import transactions. What is the maximum civil penalty that CBP could assess against Fine Furniture for Fine Furniture's violations?
Show the answer and why
A. Correct. A non-broker who transacts customs business is liable up to $10,000 per transaction, but no more than $30,000 in aggregate (19 CFR 111.91(b)). Ten transactions × $10,000 is capped at $30,000.
B. Incorrect. The aggregate cap is $30,000.
C. Incorrect. The aggregate cap is $30,000.
D. Incorrect. The aggregate cap is $30,000.
19 CFR 111.4 · 19 CFR 111.91(b) · law as of 2026-11-09
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