Roanoke Insurance Group Issues Public Comment on Customs & Border Protection Bureau Notice

WASHINGTON, July 15 -- Colleen Clarke, and Matthew Zehner, vice presidents of Roanoke Insurance Group Inc., Schaumburg, Illinois, has issued a public comment on the Customs and Border Protection Bureau's notice entitled "Commercial Customs Operations Advisory Committee". The comment was written on July 13, 2020, and posted on July 14, 2020:

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We respectfully submit the following public comment to be read and discussed during the COAC public meeting on July 15, 2020. Roanoke Insurance Group Inc. is a surety agent and has provided customs bonds to the international trade community since 1935.

Bond Working Group - FTZ Operator Bond Calculation

The discussion on setting a standard bond calculation for foreign trade zone operator bonds has been on the Bond Working Group's agenda since 2019. It is imperative that this issue be resolved without further delay.

We have seen an increase in the number for FTZ bond requests in the past year. Many importers are looking for ways to defer duty payment, especially during these hard economic times. One way is to enter imported goods into a foreign trade zone for future formal entry and distribution. A current request is for a company planning to move its manufacturing back to the U.S. and perform light manufacturing in an FTZ. Not only does this boost the economy in the FTZ location and adds jobs, they are following the intent of the Administration by bringing manufacturing back to the U.S. The only obstacle is determining the bond amount.

By not standardizing a reasonable bond amount formula, CBP is impeding these companies' ability to save money during hard economic times. Furthermore, CBP is also hindering the goal of the Administration to promote or restart U.S. manufacturing and add jobs because companies are holding back implementing their FTZ plans. Further inaction by CBP may drive FTZ activity away from the United States.

Respectfully,

Colleen Clarke, Vice President

Matthew Zehner, Vice President

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The notice can be viewed at: https://www.regulations.gov/document?D=USCBP-2020-0033-0001

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