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ZX Customs Brokers, Inc. (ZX) is a customs broker that is a corporation. George Forest, an individually licensed customs broker, is ZX's Vice President of Compliance and is the qualifier for ZX's license and national permit. On May 1, 2025, the Executive Director, Office of Trade, CBP accepts Mr. Forest's voluntary suspension of his individual license for one year effective May 5, 2025 due to health issues. ZX's Import Manager, Jayne Smythe, is an individually licensed broker, but she is not a duly appointed officer of ZX. Which of the following statements is FALSE?
The false statement is the plan to name Ms. Smythe only as permit qualifier and carry on until a supposed December 31 permit expiry. A corporate license needs at least one officer who is a broker (19 CFR 111.11(c)(2)); with no licensed officer for 120 continuous days (from 5 May 2025 that ends 2 Sep 2025) the license and permit are revoked by operation of law under 111.45(a). A non-officer can qualify the permit, but that does not cure the license gap, and national permits do not expire each December 31. Appointing her an officer, hiring a licensed officer before 2 Sep 2025, or a voluntary suspension under 111.52 are all permitted. Source: 19 CFR 111.11(c)(2); 111.19(a)-(b); 111.30(b); 111.45(a); 111.52 (2024 ed.; unchanged in eCFR as at 7 Oct 2026); 120 days from 5 May 2025 = 2 Sep 2025 (computed). CBP answer key: A. CBP's citation: 19 CFR 111.52; 19 CFR 111.11(c); 19 CFR 111.19; 19 CFR 111.45.
Candidates see that an employee may qualify the national permit and miss that the corporate license still needs a licensed officer within 120 days.
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