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SFAA submits comments to Customs and Border Protection regarding implementation of the ebond test

Wednesday, December 17, 2014  
On December 15, 2014, SFAA submitted comments to Customs and Border Protection (CBP) regarding the implementation of the ebond test, whereby single transaction bond and continuous transaction bonds may be submitted electronically. SFAA staff participated in several working groups and conference calls with CBP throughout the year.  During these meetings, SFAA expressed that it was critical for the electronic bond process to include certain formalities to ensure a valid and binding obligation.  In particular, there should be a writing describing the key terms of the bond contract, and the process should manifest the surety's intent to be bound by those terms.  The notice implementing the ebond test indicates that these formalities will be present.

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