Federal Register - September 10, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 173 / Friday, September 10, 2021 / Proposed Rules TABLE 28BROKER COSTS UNDER A 72-HOUR CONTINUING EDUCATION REQUIREMENTContinued 2021 U.S. Dollars Low Year
Cost 2023
2024
2025
2026
Medium
High
Brokers Total
Cost
Total
Cost
Total
13,822
14,867
14,867
14,867
62.54
62.54
62.54
62.54
518,657
557,880
557,880
557,880
1,248
1,248
1,248
1,248
10,348,863
11,131,490
11,131,490
11,131,490
2,193
2,193
2,193
2,193
18,188,702
19,564,211
19,564,211
19,564,211
Total
14,867
375
3,229,610
7,487
64,441,059
13,159
113,258,739
Totals may not sum due to rounding.
Alternative 2: 36 hours every three years.
Alternative 2 is the chosen alternative.
Alternative 3: CBP list of brokers voluntarily meeting continuing education standards.
Under Alternative 3, instead of mandating any kind of continuing education program, CBP would release annually a list of brokerages or companies employing brokers who voluntarily provide continuing education to their broker employees. As with Alternative 1, qualifying events would include internal training, government-sponsored webinars, trade conferences and events, and other activities. CBP would draft this list each year by requesting that companies report whether they provide a continuing education program. CBP
might request details from the company to ensure the training provided meets a certain threshold for quality and relevance.
Under baseline conditions, CBP
estimates that about 60 percent of brokers already complete continuing education on a voluntary basis. CBP
does not believe that publishing a list of brokerages that provide continuing education would induce the remaining 40 percent of brokers to pursue continuing education, though some brokers might do so. Under Alternative 3, those individual brokers who already complete ongoing training would continue to do so, while many of those brokers who do not, would not, absent a mandate, be likely to change. CBP
estimates that an additional five percent of brokers might begin a continuing education program in order to be
included on CBPs list, representing about 186 additional companies.85
While fewer brokers would face the costs of tuition, travel, and recordkeeping, approximately 743 would face these costs of continuing education over the 6-year period of analysis.
Additionally, CBP would incur the costs of composing the list each year and companies employing brokers would face the costs of applying to be included on the list. Assuming two CBP
personnel spend about 40 hours each, annually to compose the list, that one person from each company spends about 10 hours compiling and submitting information to CBP annually, and that one third of affected brokers choose each cost path, Alternative 3
results in costs of $5,636,739 over the 6year period of analysis. See Table 29.
TABLE 29TOTAL COSTS UNDER ALTERNATIVE 3
2021 U.S. Dollars Year 2021
2022
2023
2024
2025
2026
CBP cost
Brokerage costs
Broker costs
Total
$11,840
11,840
11,840
11,840
11,840
11,840
$267,605
267,605
267,605
267,605
267,605
267,605
$293,545
695,303
725,822
748,466
748,466
748,466
$572,990
974,748
1,005,267
1,027,911
1,027,911
1,027,911
Total
71,040
1,605,631
3,960,068
5,636,739
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Totals may not sum due to rounding.
If only 5 percent more brokers elect to begin continuing education under the terms of Alternative 3, fewer noncompliance actions would be avoided.
CBP estimates that only an eighth as many penalties and audits would be
avoided as compared to Alternative 2.
Therefore, CBP and brokers would avoid three penalties and one audit annually, for a total cost savings of $44,955 per year. However, CBP does not typically include avoided penalties in the overall
accounting of costs and benefits of a rule. Therefore, over a 6-year period of analysis, Alternative 3 leads to $248,600
in cost savings.
85 CBP assumes that large companies employing more than 100 people already have a continuing education program. Therefore, those companies that
would need to add continuing education in order to be included on CBPs list would likely be small to medium sized businesses, meaning there would
be a significant number of them, employing a few brokers each.
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