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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Proposed Rules
or 81 hours over a 6-year period of analysis, to comply with the rule.
Some brokers would choose to complete their trainings outside of work hours, while others would complete training as part of their assigned duties.

Brokers would also spend time in researching, registering for, and maintaining records of their continuing education, for a total of 12 hours per year of training plus 1.5 to 1.75 hours per year in research and recordkeeping.

Based on the average wage rate for brokers of $31.27, the opportunity cost of researching, registering for, attending, and reporting continuing education is approximately $14,547,191 over the 6year period of analysis.71 See Table 11.

TABLE 11SUMMARY OF OPPORTUNITY COST FOR BROKERS
2021 U.S. dollars Year 2021
2022
2023
2024
2025
2026

Brokers
Hours
Wage rate
Cost

5,529
5,529
5,529
5,947
5,947
5,947

13.5
13.5
13.5
13.5
13.5
13.5

$31.27
31.27
31.27
31.27
31.27
31.27

$2,333,955
2,333,955
2,333,955
2,515,108
2,515,108
2,515,108

Total

5,947

81

187.62

14,547,191

Totals may not sum due to rounding.

Total costs for all individual brokers, including tuition and travel expenses for those who must begin continuing education regimens because of the rule
as well as opportunity and reporting costs for all brokers, range from $16,452,050 to $53,128,426. The primary estimate, which accounts for
one third of brokers choosing each cost tier, comes to $35,478,781 over the 6year period of analysis. See Table 12.

TABLE 12TOTAL COSTS FOR ALL BROKERS
2021 U.S. dollars Total cost:
low estimate
Year 2021
2022
2023
2024
2025
2026
Total

$2,636,505
2,636,505
2,636,505
2,847,512
2,847,512
2,847,512
16,452,050

Total cost:
medium estimate $5,913,241
5,913,241
5,913,241
6,372,048
6,372,048
6,372,048
36,855,867

Total cost:
high estimate $8,526,520
8,526,520
8,526,520
9,182,956
9,182,956
9,182,956
53,128,426

Total cost:
primary estimate $5,692,089
5,692,089
5,692,089
6,134,172
6,134,172
6,134,172
35,478,781

Totals may not sum due to rounding.

To implement the requirements of the proposed rule, CBP would need to designate entities or companies as approved accreditors of customs broker continuing education. To do so, CBP
would solicit applications from parties interested in becoming accreditors, or following the first application cycle accreditors seeking renewal of their status, by publishing a Request for Proposal RFP.72 A panel of CBP
experts would evaluate the applications
and select the entities approved or renewed as accreditors. CBP estimates that the process of developing and submitting the RFP would take two personnel 10 hours. Application evaluation would take a further 40
hours and would require four CBP
personnel. The process of designating accreditors would occur before the continuing education requirements went into effect, to allow accreditors to be ready for the rules implementation and ensure equal footing for all providers.73 However, because of
uncertainty over timing of the rules implementation, we assumed that designation of accreditors would occur in the first year of the period of analysis.
Regardless of when the rule goes into effect and the designation process occurs, accreditors and CBP would need to complete the process two times in a 6-year period. Overall, designation of accreditors would require six CBP
personnel 180 hours total, twice in a 6year period of analysis, for a cost to CBP
of $26,640 see Table 13.

71 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 2004
December 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.
72 See proposed 19 CFR 111.103c.
73 See section IV.E.1. of this NPRM.

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