Important Notice to Importers:

There are other reasons CBP may decide a bond is insufficient, and some of them require that action be taken immediately, without notice to the importer.

Please contact us at import@argents.com if you have had the following problem or any other CBP related issues.

The following are the reasons cited by CBP for a bond to be rendered insufficient:

• Outstanding debt issues related to any of the entities on the bond (including unpaid bills and debit vouchers)
• Failure to comply in a timely fashion with a formal demand letter from CBP to increase the bond
• Failure to correct an invalid importer of record address for any entity using the bond
• Failure to comply with the rejection of a termination request
• Missing or misplaced bond paperwork
• Use of an invalid importer of record number on the bond (ex. an entity using an EIN that is not assigned to that party by the IRS)

Occasionally branches of the government work together and share information. CBP compared the IRS (NN-NNNNNNN) and SSN (NNN-NN-NNNN) format importer numbers it has accumulated over the past 20 years against what the IRS shows to be valid numbers. Tens of thousands of numbers turned out to be invalid.
About 1000 of these were on in force continuous bonds. CBP recently rendered these bonds insufficient so that importers could no longer use the bond and they would have to correct the situation.

Correcting the situation means either:

1. Documenting to CBP that the importer number is correct (this is done by showing CBP evidence, such as some documentation FROM the IRS TO the importer showing the correct tax payer identification number (a tax return does not work here), and this document must be dated within the past 2 years, or
2. Filing a term and replace with the new bond showing the correct information.

CBP did not send out letters or give importers time to comply. As stated on the last page in their, "Latest News" doument, the use of an invalid importer number is grounds to render a bond insufficient.

A bond that is rendered insufficient is not terminated, but it is not longer available for prospective transactions. CBP can always change the insufficient status of a bond, so if such a bond needs to be terminated, proper notice must be given as required by 19 CFR 113.27 .

Additional Resources: U.S. Customs website.