Avalon is committed to providing the highest level of service to our clients and has always taken a proactive approach to understanding ISF.
Background
The Importer Security Filing (ISF, commonly known as "10+2") is an initiative created by U.S. Customs and Border Protection (CBP). The rule requires advance cargo information to be transmitted to CBP at least 24 hours before goods are loaded onto an ocean vessel for shipment to the United States. ISF was created for security reasons, pursuant to the SAFE Port Act. Importers are required to provide 10 data elements to CBP, while carriers provide 2 data elements.
The rule was published in the Federal Register on Nov. 26, 2008 and went into effect on Jan. 26, 2009. During the first year, CBP used a phased-in approach, where importers were warned of infractions. After the initial phase-in period, on Jan. 26, 2010, ISF became fully effective.
We have worked closely with Customs officials to develop ISF guidelines that met the needs of the brokerage industry, while recognizing the significant penalty exposure ISF presents. To support our valued customers, we have prepared the following materials:
• Sample letter to assist in communicating ISF to importers
• A copy of the Q&A compiled from our general ISF and Web Merlin webinars.
• A live recording of our ISF Webinar held Dec. 18, 2009.
Please also view our ISF Quest archives:
• March 2011: ISF Enforcement – Where we are now and what to expect
• Aug. 18, 2010: CBP updates including ISF enforcement
• March 5, 2010: CBP announces ISF rejection reasons, Web Merlin updates to avoid rejections
• Jan. 26, 2010: CBP releases timeline of ISF enforcement
• Jan. 20, 2010: Web Merlin updates to support ISF Bond Issuance
• Jan. 15, 2010: ISF Appendix D continuous bonds not advantageous for importers
• Dec. 28, 2009: CBP posts ISF Bond guidelines
• Dec. 12, 2009: Announcing ISF enforcement and Avalon’s ISF Webinar series.
Web Merlin™
Web Merlin continues to provide the best surety bond technology in the industry and will assist in managing your ISF compliance with underwriting automation, compliance messages and e-mail notification of ISF Bonds. Our portal offers a streamlined approach to issuing ISF Bonds and transmits the bond directly to CBP to support your compliance with the ISF rule. Web Merlin also contains several business rules to avoid rejections. We are currently programming Web Merlin to accept collateral online via EFT or credit card transaction in instances when it will be required. This will ensure quick and timely issuance of ISF-D Bonds to support your operation.
Avalon is also currently working on three key ISF issues, including assisting the NCBFAA in drafting a white paper to propose shortening the six-year statute of limitations currently in place for ISF, working through the ITSA to dispute CBP’s efforts to “double dip” against any and all Customs bond types for ISF claims, as well as outreach with various trade associations.
We thank you for your business and the time in reviewing our ISF materials, attending our webinars and learning more about our Web Merlin updates. We understand the significant impact that ISF has on your business and if you have any questions, please do not hesitate to contact your local Avalon office.
