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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Proposed Rules TABLE 26PRIMARY ESTIMATE OF NET PRESENT AND ANNUALIZED COSTS
2021 U.S. Dollars 3%

7%

PV

AV

PV

AV

Savings
Costs

$1,795,619
32,570,459

$331,467
6,012,425

$1,579,949
28,584,851

$331,467
5,996,982

Net Costs

30,774,841

5,680,959

27,004,902

5,665,515

CBP presents four estimates of the net costs depending on the cost of training pursued by each individual broker. The low-cost path assumes the broker would pursue only free trainings and forgo travel. In the medium-cost path, brokers would pursue a mix of free and paid trainings and travel to a single
annualized cost ranging from $2,514,956
to $8,617,817, using a 3 percent discount rate over the 6-year period of analysis. A summary of net costs under all four estimates presented in the analysis can be found in Table 27.

conference or in-person event per year.
In the high-cost path, brokers would pursue all paid trainings and travel to two in-person events or conferences per year. The primary estimate assumes that one third of brokers would choose each path. Overall, the quantifiable effects of the proposed rule result in a net,
TABLE 27SUMMARY OF NET COSTS
2021 U.S. Dollars Estimate
Value
Primary
Low
Medium
High

As stated before, many benefits of the proposed rule are qualitative. Brokers would benefit from improved reputation and a professionalization of the customs broker community while their clients would benefit from better performance, less non-compliance, and improved outcomes. Providers would benefit from increased prestige due to CBP-approved accreditation. CBP believes that the combination of quantified benefits and unquantified benefits exceed the costs of this rule. We request comment on this conclusion.
9. Analysis of Alternatives Alternative 1: 72 hours every three years.
Alternative 1 is the same as the chosen alternative except that the
Net Net Net Net Net Net Net Net
PV
AV
PV
AV
PV
AV
PV
AV

3%

7%

$30,774,841
5,680,959
13,624,000
2,514,956
32,016,156
5,910,102
46,684,367
8,617,817

$27,004,902
5,665,515
11,945,324
2,506,079
28,094,859
5,894,183
40,974,522
8,596,283

inappropriate for individual brokers.
Were CBP to mandate 72 hours of continuing education every three years, brokers who already voluntarily pursue continuing education would need to increase the amount of training they complete, often by 100 percent. Costs incurred by both brokers who do not already pursue continuing education and those who do would be much greater. Such a requirement would be too onerous, particularly for small businesses, which make up a significant proportion approximately 39 percent of the employers of licensed customs brokers. CBP estimates that such a requirement would cost brokers up to $113,258,739 over a 6-year period of analysis, or about $7,618 per broker. See Table 28.

continuing education requirement would be raised to 72 hours each triennial cycle instead of 36 hours. This alternative is modeled on the Internal Revenue Services IRS Enrolled Agent program, which requires 72 hours of continuing education every three years.84 An enrolled agent is an individual who may represent clients in matters before the IRS and, like a licensed customs broker, must pass a rigorous examination to prove his or her knowledge and competence, making it a reasonable analog to the proposed CBP
program. Once the agent has passed the exam, he or she has unlimited practice rights, providing he or she completes the requisite continuing education.
CBP has determined that 72 hours every three years would be
TABLE 28BROKER COSTS UNDER A 72-HOUR CONTINUING EDUCATION REQUIREMENT

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2021 U.S. Dollars Low Year
Cost 2021
2022

13,822
13,822

20:35 Sep 09, 2021

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Total
$62.54
62.54 I

84 See Internal Revenue Service, Enrolled Agent Information Apr. 6, 2021, available at https

VerDate Sep<11>2014

Medium
High
Brokers Cost
$518,657
518,657

I

$1,248
1,248 I

Total
Cost
$10,348,863
10,348,863

I

www.irs.gov/tax-professionals/enrolled-agents/
enrolled-agent-information.

PO 00000

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Fmt 4701

Sfmt 4702

E:FRFM10SEP2.SGM

10SEP2

$2,193
2,193 I

Total $18,188,702
18,188,702