U.S. & International Trade Compliance Study & Test Preparation

Finding the Forest in the April 2010 Exam

The April 2010 Customs Broker License Exam (CBE) is now history, though its effects will reverberate for several weeks and even months, especially for the 1000+ examinees around the country who took it.  Salute them, commend them, admire them should all of us who know what a trial that experience can be.  And, it was a trial this time, primarily because of the somewhat convoluted character of several questions.

The exam, it turns out, differed from the October 2009 CBE in that it contained far fewer repeat questions, although it did contain some.  But, it also differed from the April 2009 CBE by its inclusion of several tricky questions that required longer and more complex analysis.  The ability to authorize subagents through use of a power of attorney, for example, was a topic of more than one question, one that the most seasoned experts on the CBP regulations would find challenging even in a non-test environment.

For those trying to overcome the CBE to obtain their license, these type of questions and the overall level of impenetrability of the exam are no doubt frustrating and demoralizing, especially after having spent countless hours amassing a base of knowledge and understanding that one might reasonably hope to be sufficient to pass an exam on U.S. customs regulations.  Does it really matter if a broker knows that a power of attorney issued by a “resident principal” cannot authorize an agent to issue a subagent a separate power of attorney, unless that primary agent is a licensed customs broker?  Maybe, but what about all of the other basics of broker compliance?

You have to know those, too, would be the likely response.  It may well be that to navigate the exam process successfully you must know how to deal with complex and sometimes convoluted questions on relatively unfamiliar parts of the regulations.  Unfortunately, that does not mean you can skip the fundamentals.   Imagine trying to answer the power of attorney questions on subagency without knowing, for example, what a power of attorney is and does in the context of U.S. customs transactions.

So, the exam is, as they say, what it is.  There will always be a weird question or two (or three or four) or a section or two that seems to never end.  The only thing predictable about it is that it is unpredictable.  For that reason alone, solid preparation is an absolutely vital necessity.   You do have to go through the basics and establish a sure footing in order to respond effectively to the odd scenario or unfamiliar phrase on the exam.  Without that groundwork, the questions will seem not only somewhat puzzling, but totally unapproachable.

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