TSN Members Set to Discuss PSC Issues on Dec 7
Trade Support Network (TSN) Committee members are expected to meet on December 7, 2011 to discuss a number of Automated Commercial Environment (ACE) topics, including ongoing issues with Post Summary Correction (PSC), such as its functionality in the ACE Portal, the visibility of data elements for original entry summary filers, and the possibility of using the PSC framework to transition ACS drawback to ACE.
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According to trade sources, the issues that were summarized in U.S. Customs and Border Protection's September 2011 TSN Monthly Committee Report on ACE topics, which focused on PSC issues, will be on the agenda for the December 7 TSN meeting, as well as other items. (See ITT's Online Archives 11110326 for initial summary of this report.)
The PSC issues that must still be resolved include:
Using PSC to Correct Summaries One at a Time (Later by Batch)
The TSN is discussing splitting a GIF (Great Idea Form) on PSC Portal Functionality into two GIFs and focus first on the ability to correct entry summaries one summary at a time via the ACE Portal; the second GIF would be focused on batch uploads of corrections.
(Importers have felt that their ability to correct their entry summaries had been taken away since CBP will no longer accept paper Post Entry Amendments (PEA) from the importer if the entry summary was filed in ACE. Today many importers prepare their own PEAs.)
Clarifications on Visibility for Original Filers, de Minimis Amounts, AD/CV, Etc.
The TSN is seeking clarification on a number of issues related to PSCs, including:
- the visibility of data elements (for the original entry summary filer vs. the PSC filer) once a PSC is filed, and whether the original filer will have the same level of visibility to data as was available before the PSC was filed;
- whether for purposes of a refund, de minimis amounts will be reflected in the record (i.e, recorded in the liquidation amounts);
- whether a PSC that converts from a 01 entry type to a 03 immediately goes for team review and if it requires a cash bond; and
- additional guidance from CBP on (1) whether the obligation of the broker to retain records is satisfied by maintaining the entry data elements in the electronic form in which they were filed or whether there is also an obligation to produce the CBP forms even though these were not created at the time the entry/entry summary was filed; and (2) what records the importers are required to produce upon CBP request.
Possibility of Using PSC Framework to Transition ACS Drawback to ACE
The TSN has been discussing the possibility of using the PSC framework to transition ACS drawback to ACE. One idea discussed was that, since PSC is an adjustment to an entry, filing a drawback entry could be considered an adjustment to an entry because the drawback claim designates import entries for certain duty amounts which are refunded.
A PSC code could be used for drawback and the code would define certain elements particular to drawback. The system would then do certain edits based on the code. The drawback entry would have an identifier that gets tagged to an import entry so all import entries could be rolled up to recreate the drawback claim. Missing pieces that would need to be developed are the financial function of payment of the duty refund and a link to an electronic export system for the proof of export.