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COAC and CBP Discuss Account Based Processing Projects

Minutes from the March 9, 2010 through April 20, 2010 meetings of the COAC Trade Facilitation Subcommittee have recently been posted to CBP’s Web site. During these meetings, the Subcommittee addressed a number of trade facilitation issues, highlights of which include:

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Identification of Priority Account Based Processing Projects

During the meetings, the Subcommittee discussed with CBP officials the possible Account Based Processing (ABP) projects that CBP should undertake, which such projects should be CBP’s priority, and the scope of the priority projects. CBP and COAC have previously stated that such work is preparation for building a business model for piloting some of the priority projects.

(In May 2009, COAC submitted to CBP a white paper advocating a broad new ABP concept that would encompass trade compliance, informed compliance, security, intellectual property rights, import product safety, and information technology. CBP has previously stated that it has identified approximately 20 possible ABP projects in 4 categories: (i) commercial account processing; (ii) security account processing; (iii) information technology; and (iv) interagency interaction.)

Subcommittee Wants Centers of Expertise to be Top Priority ABP Project

During the March 16, 2010 meeting, the Subcommittee proposed to CBP that Centers of Expertise (COEs) be the top CBP priority ABP project.

The possible COEs discussed during the April 6, 2010 meeting were Miami’s processing of cut flowers, CBP’s drawback centers, international finance center, and centralizing the processing of entry summaries. The Subcommittee stated that it would provide input to CBP on additional areas where they think CBP could have a COE.

(One of COAC’s recommendations in its May 2009 white paper was the establishment of COEs for specific industry sectors at certain ports with the goal of achieving more industry commodity expertise, greater uniformity of treatment of specific product categories, and promote informed compliance.)

Other Top Projects are Managing Riskiest Entities, Progressive Enforcement

At the March 23, 2010 meeting, the Subcommittee agreed to cluster the priority ABP projects into groups and agreed to move COEs, Managing Riskiest Entities and Progressive Enforcement to the top cluster.

Finalization of Trade Facilitation Definitions and Measures

During these meetings, the Subcommittee members and CBP officials also worked to finalize the definitions and measures of trade facilitation. (The Subcommittee and CBP have been working to identify ways to help CBP understand how the trade would measure success if ABP changes are implemented.)

COAC Trade Facilitation Committee minutes available at http://www.cbp.gov/xp/cgov/trade/trade_outreach/coac/subcommittee_activities/trade_facilitation/

BP Note

At the February 25, 2010 COAC meeting, one Trade Facilitation Subcommittee member noted that the fiscal year 2011 budget request for CBP automation modernization provides only for Automated Commercial Environment (ACE) maintenance, and not for ACE development. This member expressed concern that this could adversely affect the piloting of ABP projects as there may not be funding for a project’s programming, etc.

[See ITT’s Online Archives or 03/16/10 news, (Ref: 10031605), for BP summary of CBP officials’ discussion of upcoming ABP projects at the February 25, 2010 COAC meeting.]