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ACE – The Important Points Going Forward. Cindy Allen – NCBFAA Educational Institute Director. Agenda. ACE – A History & Background Roll Out Schedule ACE – How and What Can Be Filed? Differences in ACS and ACE Points to Remember New CBP Documents What’s Up Next? Other Concerns.
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ACE – The Important Points Going Forward Cindy Allen – NCBFAA Educational Institute Director
Agenda • ACE – A History & Background • Roll Out Schedule • ACE – How and What Can Be Filed? • Differences in ACS and ACE • Points to Remember • New CBP Documents • What’s Up Next? • Other Concerns
ACE- A History • Automated Commercial Environment • What is the TSN and Why it is Important • History • Pre 9/11 • After 9/11 • Participants • Developments • Changing Face of TSN
The Different “ACE’s” • CBP ACE System • ACE: Portal • ACE: E-Truck Manifest • ACE: Processing System • Different Development Teams • Entry Summary and Account Revenue • Release • Multi-Modal Manifest • Accounts / Legal Policy
What Can Be Filed? Entry Types 01 and 11 can now be processed in ACE • Except for the following: • Must be scheduled for a statement • No Lacey data • No FDA or DOT data can be included if the cargo was released under one of the border release systems (BRASS, FAST, Rail Line Release) • RLF is not included in the initial deployment, testing being completed now
Future ACE Releases • M1 – Vessel & Rail Manifest • M2 – Air Manifest • ESAR A2.3 • “03” Entry Types • All Entry Types • Release • All OGA’s and ITDS • Reconciliation, Export, Drawback, E-Bond
Differences in ACS & ACE: Documents Required • New Mind Set by Brokers • New Process Separates Statement & Docs Required • Daily Statement now serves several purposes • Docs Required • Payment • Checks and Balances Internally • ABI Message Sent Separately • Up to 30 Days After Release, 5 Days to Respond • Document Transmittal Sheet • Receive Message Sent by CBP • Similar to RLF Docs Required Message • Training Needs • Fundamental change in flow of entries
Differences in ACS & ACE:Census Warnings • Filer may enter preemptive Census Warning Override code at the transmission of the ACE Entry Summary • Census Warnings will: • No longer require the submission of paper Entry Summary documentation • Automatically generate an Entry Summary Reject Status • Filer may correct entry summary data by retransmitting • Census Warning Override codes can be transmitted via ABI
Differences in ACS and ACE:Entry Summary Rejects • No More “Pink Reject Sheets” • CBP users will trigger outbound ABI reject messages • Filers have two business days to respond • Paper responses can be accompanied by a reject template downloadable from CBP.gov • See Entry Summary Business Process Document • ACE rejects will be utilized in conjunction with an ACS reject to inactivate an ACE Entry Summary
Declarations in ACE Portal • Blanket declarations can be created in ACE to support both ACS and ACE entry summaries and can be viewed nationally by CBP • Type of Declarations • Affidavit of Manufacturer • Importer Certifying Statement • North American Free Trade Agreement (NAFTA) Certificate of Origin • Non-reimbursement Blanket Statement (Anti-Dumping / Countervailing Duty (AD/CVD)) • Brokers will need account access to the Importer’s Account, until end of year.
Edit LITE: Still a Concern • Increase in Liability • Instead of up front edit checks – this becomes a post entry audit function for CBP • Broker Internal Review Process • One Entry Summary Transmission • One Step vs. Two Step Process • Software Becomes Critical • Training for Employees • Technical or CATAIR Understanding by Operational Staff • Process Understanding by IT
Decide Your Deployment Schedule • Two Sets of Systems, Two Sets of Process, Two Sets of Headaches • System Determined or Manual Process? • Changes After the Fact? • 01 Type Entry Changing to 03 Type Entry • Training Employees for the Overlap • Importer Awareness of the two Systems • Information in ACE Portal • Abilities between the two system • Inconsistencies Between the Two Systems
Interaction • With Clients • Data on ACE Portals • Additional Contact With CBP Directly • With Other Parties – ACE Accounts • Surety Companies • Carriers • Transportation Firms • Warehouse / CFS Locations • With CBP • Much More Comprehensive Picture • Brokers • Importers
Problem Contingency Plans • Work with CBP on Local level to develop plans • NCBFAA is working with HQ level • Once developed share those plans with other NCBFAA member associations • Develop plans internally • Get your IT and Operations people at the same table • Go through the release scope • Develop actions from each perspective • Communication, Communication, Communication, Communication
Business Aspect of Change • This is much more than a system change • We need to look at • Internal Processes • Employee Training • System and Equipment Need • Client Interaction and Education
New CBP Resource ACE Entry Summary Filing Instructions • Developed at the request of Trade • More robust than the existing CBP Form 7501 instructions • Only pertains to transmitting data elements needed for type 01 and 11 entry summaries • Contains links within the document to more detailed sources of information impacting summary filing
New CBP Resource Business Rules and Process Document • Internal (CBP) and external (trade) versions addressing processing from each perspective • Process flow and business rules surrounding the ACE entry summary • Should serve to demystify what is occurring systemically in ACE pertaining to entry summary • Provides transparency
What is Coming Next? Post Summary Correction • No Changes After Time of Release • Analysis of Current Retransmissions • One Step vs. Two Step • Client Visibility via ACE Portal • System Edit, Checks, Stops • Visibility to CBP • Reason Codes • Successive Changes • Importer or Broker Issues • Compliance Measurements Results
What is Coming Next?Post Summary Correction • Corrective Process • Electronic vs. Manual Process • Recordkeeping Issues – Keeping all versions • Denial by CBP – Affect on Funds Paid • Approval - Refunds of Funds Paid • Training Needs • Employees • Clients • System / Equipment Needs • Additional Capabilities • Tracking / Flagging Abilities
What is Coming Next? • Imaging • Abilities of System • Storage Needs • Training • Linking to Shipments • More Portal Reports • In-Bond Revisions • Regulatory Change • Automation Limitations
Other Concerns • CBP is out of $$$ • NCBFAA White Paper • Process Flow Chart • Current TSN – November 5th • Gathering of Trade Representatives • Prioritization of Functionality • Result will be a Development Plan for CBP
Thank You! Have a Great Day! Cindy Allen NCBFAA Educational Institute Director