An Editor's Note: with Release 2 now having no set date, as of Feb 2022, kindly bare this in mind while reading.
Next month, the Canada Border Services Agency (CBSA) Assessment and Revenue Management (CARM) is scheduled to release phase 1 of the CARM Client Portal (CPP). In this blog we will discuss how you can assign your CCP to a third party along with a few tips on how to make the process smooth. Delegating your CARM account management is a fairly easy process, however due care should be paid when assigning such an important role.
Tip 1: Choose A Third Party That Is Familiar With Your Import Activity
The CCP is part of CARM Release 1 and is scheduled to be available on May 25, 2021. This marks the beginning of changes to the Broker/Importer relationship.
Importers will need to register on the CCP, get familiar with the payment and bonding system; and revise their payable processes to meet the new requirements.
For importers who currently use the services of a customs broker it is reasonable to delegate authority to your broker to act on your behalf within the CCP. The portal provides online self-service access to manage the importer's customs transactions, including electronic submission of corrections and adjustments, applying for classification rulings, and the accounting and payment of any applicable duties, taxes and fees on the imported goods. Other than the importer only authorized customs brokers will be able to perform functions within the CCP. Your broker is already familiar with your CBSA import interactions and therefore would provide a seamless transition to CARM.
Looking to have PCB manage your CARM account? Sign up here for more information as it comes available.
Tip 2: Save Time By Assigning Your Third Party To Set Up Your Account
As explained in our previous blog CARM: Your Guide to the Clients Portal the first step for all trade chain partners that conduct business with the CBSA is to register and link their business on the online CCP.
Once the CPP is accessible, clients will be able to create their individual user account and link their business account(s) on the CCP themselves or delegate it to a service provider (such as a customs broker or trade service provider).
An importer can delegate access to a customs broker for them to act on their behalf and manage their account within the CBSA CCP by establishing a business relationship. The CCP supports two (2) business relationship access types between a service provider and a client. The client determines the relationship type to grant its service provider. These two types of relationships are described as follows:
- Business Management Relationship - delegates access to all program accounts to the service provider including any programs added in the future.
- Program Management Relationship - delegates access to only selected program accounts to the service provider.
Under the Delegation of Authority (DOA) clients can assign user roles within their own business and to a third party such as a customs broker. User roles are assigned via the CCP. User roles describe how users can access business and program accounts. Here’s a quick description of the main user roles:
- The Business Account Manager (BAM) has full access to all CCP functionality for a business account and all its program accounts. The purpose of the role is to assume the management of the business account. The BAM manages all legal entity and program information and performs operational activities in the CCP such as request rulings, make payments and view financial information. The BAM should not be confused with the Business Owner or Director of a business. The BAM should be held by an individual with active involvement in the management of its business account ( ie manages employee access, manage business relationships such as third party service providers, manage business and program accounts information) The BAM is automatically given to the initial individual who links their user account to their business by completing the registration process. Due to the importance of this role it is recommended to have more than one BAM.
- The Proxy Business Account Manager or pBAM - a client can assign this role to a third party like a customs broker. The pBAM gives the broker near full access to all CCP functionality for a client’s business account. The purpose of this role is for the pBAM to assume the management of the business account of a client without interfacing with its tombstone data (business or program profiles) or access details (employees and business relationships). The pBAM has the same access as the BAM but with exceptions. A pBAM does NOT have access to the client’s sensitive information such as bank account information. A pBAM CANNOT see or manage the employees or business relationships of the client. The pBAM role is automatically given to the BAM of the service provider when they are approved for a business relationship by a client. The pBAM role can manage access only for its own employees not the employees of the client.
- The Program Account Manager or PAM - The PAM gives full access to the CCP functionality for a specific program account. The purpose of this role is for the PAM to assume management of a program account alongside the BAM. A PAM can manage program information and give access to employees for the program account. The PAM performs operational activities in the CCP such as request rulings, make payments and view account statements.
- The Proxy Program Account Manager or pPAM - This user role is for the third party program account manager. The pPAM has near full access to the clients specific program account for CCP functions. The purpose of this role is for the third party to assume the management of the Client’s specific program account without access to the clients sensitive information and access of the client’s employees or business relationships. This role is automatically given to the BAM of the service provider when they are approved for a program management relationship by the client. The pPAM has the same restrictions as the pBAM and can perform the same operational activities. The pPAM is limited only to access a specific program account.
Want to Assign Your CPP Account Management? Review our CARM Management service page for more information.
Tip 3: Ensure You Have an Agreement With Your Proxy
If a customs broker becomes your proxy BAM it involves a higher level of responsibility and risk of liability. Therefore this should only be done with an agreement or clear understanding outlining all the details. Currently your broker likely handles paying the daily notices and statements of the importers account with CBSA. With CARM the importer becomes responsible for both. You as the Importer would likely need training from your broker on how to manage this. If you want your broker to manage both for you, you need to ensure that your broker offers this type of service and even if you give access to your broker to manage the daily notices and statements of account you as the importer will still need to make your month end payments electronically directly to the CBSA.
When a customs broker is designated by their client as a pBAM or pPAM they can then assign their employees as Editors or Readers for each of the importer’s program accounts for which the customs broker has been granted access.
In addition to this delegation, a “power of attorney” agreement with your customs broker will still be required in order to conduct Customs business on your behalf. Only authorized customs brokers are able to perform import clearance and accounting for importers.
CARM places much of the account management process responsibility on the Importer. As an Importer you will need to analyze your current processes and make critical decisions on how you want to manage your day-to-day CBSA account. If you decide to take it on yourself training will need to be provided likely from your broker. Now is the time to begin the discussions with your broker and work through the processes and potential issues before May 25,2021. Don’t leave this to the last minute.