Delegation and Account Management in the CARM Client Portal

Once an importer has a business CARM Client Portal (CCP) account, they have the ability to delegate authority over their customs transactions. Through the CCP, importers can assign varying degrees of access to their own employees and third parties such as customs brokers and trade consultants. There are a variety of roles that can be assigned through CARM, with varying degrees of access and authority. Below, we’re going to look at how to delegate authority through your CCP, your options for assigning access, and some best practices for third-party access.

Roles in the CARM Client Portal

Each individual who is given access to a business CCP has to be assigned a role. The role assigned to a user determines how much access they have to information in the CCP and what tasks they can perform.

Within a business account on the CCP, different programs can be created. For example, a company might create separate programs for different regions of their operations, or different divisions within the company. The BAM will have to decide what roles to assign to their own staff and to third parties based on how much access each user needs. Programs can be used to silo CARM users according to what projects they require access to.

There are four roles that can be assigned to employees of an importer:

A Business Account Manager (BAM) has full access to everything in the business CCP. A business account manager is required to grant permission to other users who request access to the CCP, and is responsible for assigning roles to users. The person who sets up the CCP business account automatically becomes a BAM.

A Program Account Manager (PAM) is assigned to a specific program within the CCP, and within that program they have full access to everything.

An Editor can operate within a specific program (for example, submitting payments or ruling requests) but cannot manage other employees’ access.

A Reader can view the CCP but cannot alter or submit anything.

There are also two roles that can be assigned to a third party:

A Third Party Business Account Manager (Proxy-BAM or P-BAM) has similar access to a Business Account Manager, with some added limitations. They cannot see some payment information, such as credit card numbers, and do not have access to information about employees of the importer who use the CCP. A P-BAM can manage the access only of their own employees; they cannot manage the access of employees of the importer.

A Third Party Program Account Manager (Proxy-PAM or P-PAM) has full access to a single program within the CCP, also with additional limitations.
A CARM user with a personal account which is not linked to any business accounts (for example, an employee who has submitted a request that has not been responded to yet) is known as an Orphan.

In order to use the services of a customs broker, an importer needs to delegate that broker access as a third party. Importers can choose to assign their brokers either P-BAM or P-PAM status.

TIP: if you want your customs broker to take as active a role as possible in the management of your importer account, assign them P-BAM status. If you want to limit your broker’s involvement, or if you use different brokers for different programs, assign them P-PAM status.

Choosing a Third Party Service Provider
Third parties working through the CARM Client Portal will most commonly be customs brokers. As CARM is implemented, some brokers may be offering different levels of service through the CCP. If you have a customs broker currently, talk to them well in advance of CARM Release 2 (Spring 2022) and find out what CCP services they are offering. Some brokers may offer training for BAM’s and importers.

Your third-party service providers through the CCP should be familiar with your import activity and requirements, so your current customs broker is an obvious choice. CARM will require importers and brokers to work closely together, so communication regarding expectations and responsibilities is key.

If you don’t have a current broker, get a customs broker!

TIP: Delegating access to a broker through the CCP does not replace the need for a general agency agreement with the broker. An agency agreement, or power of attorney, empowers a broker to represent an importer to customs and is a legal requirement, independent of the CCP.

Responsibilities as an Importer
While importers can choose to delegate full access to their CCP to a customs broker, under CARM the responsibility for payment of customs fees and management of the business CCP ultimately falls to the importer. As an importer, you will have to monitor your CCP to make sure payments are made on time and correctly, although your broker will be able to let you know when payments are due. Your BAM will be taking an active role in managing your CBSA account, so it is important that they are familiar with the CCP and know their responsibilities.

There are lots of resources available to familiarize yourself with CARM and the CCP. CBSA offers a series of videos on how to use the CCP, and our blog has a detailed guide on setting up a business CCP. Don’t forget, one of the best resources is your own customs broker! Talk to your broker if you have any questions, or reach out to King Bros and we will do our best to assist.

TIP: Don’t wait until the last minute! Start getting your CCP set up and authority delegated as soon as you can. The system will become mandatory in Spring 2022, and the CARM users on your CCP should be comfortable with the system well in advance of the deadline.

By Robin Smith, M.A., CCS
– Robin is a trade industry professional based in Victoria, BC.

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