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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Proposed Rules TABLE 13COSTS TO CBP TO DESIGNATE ACCREDITORS
2021 U.S. dollars Personnel for RFP

Year 2021
2022
2023
2024
2025
2026

Personnel for evaluation
Wage rate
Hours
Total

2
0 0
2 0
0

4
0 0
4 0
0

$74.00
74.00
74.00
74.00
74.00
74.00

50
0 0
50
0 0

$13,320
0 0
13,320
0 0

Total

26,640

Totals may not sum due to rounding.

CBPs Broker Management Branch BMB would also face the costs of auditing for compliance with the continuing education requirement.
Although individual brokers would selfattest to their completion of the continuing education requirement with each triennial report, CBP would occasionally conduct compliance audits by randomly selecting a certain subset of brokers for auditing. To start, CBP
would select 10 percent of brokers per year, although the audits would only
cover the continuing education reported for the most recently completed triennial cycle. A continuing education compliance audit would involve CBP
personnel reviewing the reported coursework of the selected broker and potentially working with brokers to identify gaps or higher quality training opportunities. Such an activity would take approximately one hour, on average; therefore, CBP estimates that each compliance audit would cost CBP
approximately $74.00. For the first three
years of the period of analysis, no compliance audit would take place because brokers would not yet have reported their training at the end of the first triennial cycle. Over the next three years, CBP would select 10 percent of active individual brokers to audit.74
With about 1,500 compliance audits performed per year, costs to CBP would amount to $330,054 over the 6-year period of analysis. See Table 14.

TABLE 14COMPLIANCE AUDITING COSTS FOR CBP
2021 U.S. dollars Year 2021
2022
2023
2024
2025
2026

Audits
Cost per audit
Total

0
0 0
1,487
1,487
1,487

$74
74
74
74
74
74

$0
0 0
110,018
110,018
110,018

Total

4,460

444

330,054

Totals may not sum due to rounding.

iii. To Accreditors Accrediting bodies interested in becoming designated accreditors for customs brokers continuing education under the terms of proposed rule would need to apply to CBP during an open RFP period and then re-apply to confirm their status every three years. Costs to respond to the RFP include only the
preparation of the application. Overall, CBP estimates that the preparation of an application to CBP to become an accreditor would take two employees 40
hours, to be completed two times in a 6-year period. Although the application for accreditor status would likely be completed before the proposed rule is officially in effect, because of
uncertainty in the timing, we have used the same period of analysis.75
Regardless of when the rule goes into effect, accreditor-applicants would need to apply twice in a 6-year period.
Therefore, CBP estimates that CBPdesignated accreditors would incur approximately $11,339 in costs over a 6year period of analysis. See Table 15.

TABLE 15COSTS TO ACCREDITORS
2021 U.S. dollars
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Year
Personnel
2021
2022
2023
74 Those individual brokers who have not yet completed a triennial report since taking their broker exam would be exempt from completing continuing education until after their first triennial
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Wage rate 2
0 0

report and, therefore, would also be exempt from continuing education audits during that time.
75 When the proposed rule is first implemented, CBP would allow accreditor-applicants time to apply before the requirement is officially in place
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$70.87
70.87
70.87

Hours
Total 40
0 0

$5,670
0 0

so that they are able to accredit courses as soon as the rule is in effect, allowing providers equal footing and giving brokers the largest pool of potential training.

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