Importers participating in the Reconciliation Prototype Program (RPP) need to be aware that U.S. Customs and Border Protection recently started reviewing all reconciliation bond riders currently on file.
To my knowledge this is the first formal review and definitely the first time I have seen letters issued by the Commercial Operations and Policy Division advising importers they have 30 days to get a valid rider on file. I have seen approximately 20 such letters in the past month.
Better late than never, right? The RPP has been in existence for 17 years – yes, still a prototype after 17 years – and as I stated above this is the first time letters have been issued, en masse. Sure, there have been the occasional email and phone conversation but nothing this formal. So consider this a heads up!
I’m not sure what methodology CBP is using in their review but if you aren’t sure whether or not your bond rider is current, check with your surety.
I believe CBP is issuing formal letters now because eventually all continuous bonds and bond riders will need to be on file electronically – no more paper! CBP is currently conducting a test – see CSMS 14-000660 for details – of the eBond program that eventually be rolled out to all importers.
I guess you can say these formal letters are CBP’s way of getting people’s attention, both importers and sureties alike.
The point here is that you shouldn’t wait for CBP to issue your company a formal letter. If your company is currently participating in the RPP and has been for some time, check with your surety to make sure you have a valid reconciliation bond rider on file.
And while you are at it, get the details of the eBond program. Be proactive and avoid receiving a letter that gives you approximately 3 weeks’ notice to act.