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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Proposed Rules 5. Costs of the Rule i. To Brokers The primary cost to individual brokers upon implementation of the rule would be those costs associated with finding and attending 36 hours of continuing education over a 3-year period. These costs include time spent researching reputable and relevant trainings, travel and incidental expenses to attend in-person events like conferences, and the tuition or fees for the courses themselves. Many brokers might satisfy the continuing education requirement with training supplied by their employers. Other brokers, particularly those self-employed or employed by small businesses, would need to seek external training. For external training, brokers may attend free webinars, seminars, and trade events sponsored by CBP, other government agencies, and various related organizations like local freight forwarder and broker associations.59
Alternatively, brokers might choose paid trainings, conferences, or symposia, or seek certifications offered by trade organizations or educational institutions.
CBP does not know exactly which option each individual broker is likely to choose. Many brokers already hold certifications, attend webinars, and fulfill internal training requirements, though they may need to increase the number of hours completed to comply with the proposed rule. Therefore, CBP
has estimated a range of costs. Some brokers would fulfill their proposed continuing education requirements with only free trainings. Others would follow a medium-cost path by opting for a mix of free, lower-cost, and internal trainings. CBP further assumes that brokers electing the medium-cost path would travel to attend one major
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59 For example, the Florida Customs Broker and Forwarders Association offers both paid and free events. Information on CBP-hosted webinars can be found at https www.cbp.gov/trade/stakeholderengagement/webinars. Many other government agencies also provide webinars on trade-related topics. For example, in 2020, the Food and Drug Administration FDA hosted a series of webinars on the importation of medical devices in light of the COVID19 pandemic. See https www.fda.gov/
medical-devices/workshops-conferences-medicaldevices/webinar-series-respirators-and-otherpersonal-protective-equipment-ppe-health-carepersonnel-use.

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conference or symposium in-person per year. Finally, some would meet requirements by completing only paid courses representing the highest-cost offerings. CBP assumes that brokers choosing the higher-cost option would travel to attend an average of two conferences per year.
There are several organizations that provide continuing education for customs brokers, ranging from regional broker associations to national entities, such as the American Association of Exporters and Importers AAEI.
Continuing education that qualifies under the terms of the proposed rule includes webinars, seminars, and trade conferences. The hourly cost of such trainings excluding free events provided by government agencies and other organizations usually ranges from around $25 to $70. Fees are often tiered based on membership of the hosting organization. Members of an organization may pay $25 while nonmembers pay $45. CBP cannot predict which organizations would seek accreditation for their events, although all free webinars and trainings hosted by Federal government agencies would be automatically accredited. Therefore, we assume that the average hourly monetary cost would range from $0.00
low to $30 medium to $50 high.
This assumption is based on current fees charged for various continuing education certifications, webinars, and trade conferences.60
In addition to fees, individual brokers would need to spend some time in researching relevant and accredited trainings. CBP assumes that a broker would spend approximately three hours finding and registering for continuing education during every triennial period.
Many individual brokers are members of both local and national organizations that provide continuing education opportunities and would likely be notified of opportunities via newsletters or listservs. Other individual brokers would need to spend some time finding and verifying accreditation for 60 CBP does not have information on the cost for an employer to provide training internally, although such information was requested in the ANPRM.
CBP believes the cost for internal training would be closer to that of attending external trainings as a member, since member fees are likely much closer to base cost of provision than non-member fees.

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qualifying events. All individual brokers would spend some time registering for events. Based on an average fully-loaded wage rate of $31.27, the process of researching and registering for trainings would cost brokers approximately $2.61
per credit hour.61
Many individual brokers also travel to attend trade conferences each year. CBP
assumes that those brokers electing the lower-cost options would forgo travel and either attend virtually paying only the fee or not attend at all. CBP
assumes that brokers in the mediumcost tier would travel to attend one conference each year, while brokers in the high-cost tier would travel to attend two conferences.62 Tuition and fees for conferences, broken down into an hourly rate, are already accounted for in the average costs of $30$50 per hour.
Traveling to attend a single 3-day conference costs approximately $245 in airfare, $288 for lodging, and $165 for meals and incidentals, for a total of $698
for one conference or $1,396 for two conferences see Table 6.63 Spread across 36 hours of training, travel costs account for an additional $19.39 per hour medium or $38.78 per hour high.
61 Wage rate source: U.S. Bureau of Labor Statistics. Occupational Employment Statistics, May 2019 National Occupational Employment and Wage Estimates, United States. Updated March 31, 2020. Available at https www.bls.gov/oes/2019/
may/oes_nat.htm. Accessed June 12, 2020; U.S.
Bureau of Labor Statistics. Employer Costs for Employee Compensation. Employer Costs for Employee Compensation Historical Listing March 2004December 2019, Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 20042019.
March 2020. Available at https www.bls.gov/web/
ecec/ececqrtn.pdf. Accessed June 12, 2020. The wages are in 2019 dollars and CBP assumes an annual growth rate of 0 percent.
62 Some individual brokers would pay for their travel out of pocket, while other would have their travel expenses covered by their employers.
63 CBP bases these costs off the average price of a domestic flight in 2019 flight prices in 2020 were not used due to the disruptions caused by COVID
19 cancellations, and the General Services Administrations per diem cost for lodging and meals and incidentals. Source for flight costs: The Bureau of Transportation Statistics, Average Domestic Airline Itinerary Fares, https
www.transtats.bts.gov/AverageFare/. Accessed April 13, 2021. Source for per diem costs: U.S.
General Services Administration, Per Diem Rates, https www.gsa.gov/travel/plan-book/per-diemrates. Accessed April 13, 2021.

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