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NEW YORK/NEW JERSEY FOREIGN FREIGHT FORWARDERS & NEW YORK/NEW JERSEY FOREIGN FREIGHT FORWARDERS & BROKERS ASSOCIATIONBROKERS ASSOCIATION

AND AND AMERICAN SHIPPERAMERICAN SHIPPER

SEMINARSEMINAR

APRIL 27, 2011APRIL 27, 2011NEWARK, NJNEWARK, NJ

NVOCCs’ EXEMPTION FROM PUBLISHING RATES:NVOCCs’ EXEMPTION FROM PUBLISHING RATES:

HOW TO EFFICIENTLY IMPLEMENTHOW TO EFFICIENTLY IMPLEMENTNEGOTIATED RATE ARRANGEMENTSNEGOTIATED RATE ARRANGEMENTS

Carlos Rodriguez, Esq.Rodriguez O’Donnell

Gonzalez & Williams, P. C.1250 Connecticut Ave., N.W.

Washington, D.C. 20036

Direct Dial: 202-973-2999E-mail: rodriguez@rorlaw.com

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OVERVIEWOVERVIEWLEGAL CHANGES - TARIFF REFORMLEGAL CHANGES - TARIFF REFORM

• KEY ITEMS :KEY ITEMS :

*RATES ONLY IN NVO NEGOTIATED RATE *RATES ONLY IN NVO NEGOTIATED RATE ARRANGEMENTS (“NRAS”) ARRANGEMENTS (“NRAS”)

* * CHARGES: “ALL IN” O.K.; LINE ITEM CHARGES: “ALL IN” O.K.; LINE ITEM CHARGES MUST CHARGES MUST BE IN NRA/RULES TARIFF BE IN NRA/RULES TARIFF

*RATE/CHARGES INCREASES WITHOUT 30 DAY *RATE/CHARGES INCREASES WITHOUT 30 DAY NOTICE NOTICE

*AMENDMENTS TO NRA NOT ALLOWED*AMENDMENTS TO NRA NOT ALLOWED

*REGISTERED NVOCCs EXCLUDED*REGISTERED NVOCCs EXCLUDED

*EXEMPTION IS OPTIONAL , NOT EXCLUSIVE*EXEMPTION IS OPTIONAL , NOT EXCLUSIVE

*TARIFFS, NSAs CAN CO-EXIST WITH NRAs*TARIFFS, NSAs CAN CO-EXIST WITH NRAs

• RECORDKEEPING REQUIREMENTSRECORDKEEPING REQUIREMENTS

• RULES TARIFFS---NEW ROLERULES TARIFFS---NEW ROLE

• EFFECTIVE DATE: ON APRIL 18, 2011EFFECTIVE DATE: ON APRIL 18, 2011

NET EFFECT OF EXEMPTION:NET EFFECT OF EXEMPTION:

• NVOCCs EXEMPT FROM NVOCCs EXEMPT FROM PUBLISHINGPUBLISHING ITS RATES— ITS RATES—EXPENSE RELIEFEXPENSE RELIEF

• EXEMPTION EXEMPTION FROM 30 DAY NOTICE FOR FROM 30 DAY NOTICE FOR RATE/CHARGES INCREASES---RATE/CHARGES INCREASES---FLEXIBILITYFLEXIBILITY

• EXEMPTION EXEMPTION FROM ADHERING TO PUBLISHED RATE---FROM ADHERING TO PUBLISHED RATE---PENALTY RELIEFPENALTY RELIEF

• EXEMPTION FROM EXEMPTION FROM APPLYING TO FMC FOR REFUNDS APPLYING TO FMC FOR REFUNDS TO SHIPPER FOR ERRORS, ETC.---TO SHIPPER FOR ERRORS, ETC.---FLEXIBILITYFLEXIBILITY

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WHAT TO DO FIRSTWHAT TO DO FIRST

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• FIRSTFIRST: AN NVOCC MUST GIVE : AN NVOCC MUST GIVE NOTICENOTICE THAT IT WISHES TO INVOKE THAT IT WISHES TO INVOKE THE TARIFF EXEMPTION BY:  THE TARIFF EXEMPTION BY:  

(1) A PROMINENT (1) A PROMINENT NOTICENOTICE IN ITS RULES TARIFF IN ITS RULES TARIFF AND ON ITS BILL AND ON ITS BILL OF LADING OR OTHER SHIPPING DOCUMENTS, E-MAILSOF LADING OR OTHER SHIPPING DOCUMENTS, E-MAILS; ; AND AND

(2) (2) NO LONGER REQUIRED NO LONGER REQUIRED TO FILE TO FILE NOTICENOTICE ON FMC NVOCC ON FMC NVOCC FORM FMC-1 BEFORE USING NRAS. FORM FMC-1 BEFORE USING NRAS.

(3) IF YOU ARE BRINGING RULES TARIFF IN-HOUSE, YOU WILL (3) IF YOU ARE BRINGING RULES TARIFF IN-HOUSE, YOU WILL NEED TO AMEND FMC NO. 1 TO SHOW WEB-SITE ADDRESS NEED TO AMEND FMC NO. 1 TO SHOW WEB-SITE ADDRESS WHERE RULES ARE HOSTEDWHERE RULES ARE HOSTED

•   Options on FMC-1:Options on FMC-1:

A)A) MOVING ALL CARGO VIA NRASMOVING ALL CARGO VIA NRAS

B)B) MOVING ALL CARGO VIA TARIFFMOVING ALL CARGO VIA TARIFF

C)C) MOVING ALL CARGO VIA NRAS OR TARIFFMOVING ALL CARGO VIA NRAS OR TARIFF

WHAT IS A WRITING?WHAT IS A WRITING?

• UCC-§1-201 (46)---”Written” or UCC-§1-201 (46)---”Written” or “writing” “writing” includes printing, typewriting or any other includes printing, typewriting or any other intentional reduction to tangible form. intentional reduction to tangible form.

• Black’s Law Dictionary---”Black’s Law Dictionary---”WritingWriting consists consists of letter, words, or numbers, or their of letter, words, or numbers, or their equivalent set down by handwriting, equivalent set down by handwriting, typewriting, . . . Electronic recording . . . typewriting, . . . Electronic recording . . . or other form of data compilation.”or other form of data compilation.”

• A collection of e-mails would qualify if they A collection of e-mails would qualify if they contained all the rates and terms (names, contained all the rates and terms (names, addresses of parties). addresses of parties). No signatures No signatures required, but the e-mails should be clearly required, but the e-mails should be clearly to/from the shipper to/from the shipper and bind the partiesand bind the parties..

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WHAT IS AN NRA? WHAT IS AN NRA? “Negotiated Rate Arrangements ““Negotiated Rate Arrangements “

• FMC DEFINITION: “NVOCC Negotiated Rate Arrangement FMC DEFINITION: “NVOCC Negotiated Rate Arrangement means a means a writtenwritten and and bindingbinding arrangement between a arrangement between a shipper and an shipper and an eligible NVOCC eligible NVOCC to provide specific to provide specific transportation service for a transportation service for a stated cargo quantitystated cargo quantity, from , from origin to destination origin to destination on or after receipt of the cargo by on or after receipt of the cargo by the Carrier or its agent, the Carrier or its agent, etc.etc.””

WHAT IS A WRITING? WHAT IS A WRITING? E-MAILS ok; SIGNATURES E-MAILS ok; SIGNATURES NOT REQUIRED; BEST PRACTICES—USE EXISTING NOT REQUIRED; BEST PRACTICES—USE EXISTING DOCUMENTATION---QUOTE SHEETS, BOOKING DOCUMENTATION---QUOTE SHEETS, BOOKING CONFIRMATIONS, ETC. CONFIRMATIONS, ETC. NOT BILL OF LADING.NOT BILL OF LADING.

WHAT IS A WHAT IS A “BINDING“ “BINDING“ ARRANGEMENT?ARRANGEMENT? ELIGIBLE NVOCC? ELIGIBLE NVOCC? ONLY LICENSED NVOSONLY LICENSED NVOS ““STATED CARGO QUANTITIES”---STATED CARGO QUANTITIES”---DOES NOT DOES NOT

MEAN MQCS. CAN MEAN SINGLE SHIPMENT OR MEAN MQCS. CAN MEAN SINGLE SHIPMENT OR NO. OF SHIPMENTS. CAN HAVE MAXIMUM NO. NO. OF SHIPMENTS. CAN HAVE MAXIMUM NO. OF SHIPMENTS. Expiration dates. OF SHIPMENTS. Expiration dates. WHY 30 DAY WHY 30 DAY MODEL?MODEL? 66

WHAT IS A WRITING? continuedWHAT IS A WRITING? continued

• DISCUSSION POINTS: WHAT ARE YOU USING DISCUSSION POINTS: WHAT ARE YOU USING NOW TO COMMUNICATE RATES/CHARGES?NOW TO COMMUNICATE RATES/CHARGES?

(MAKING YOUR NRA BUSINESS FRIENDLY---(MAKING YOUR NRA BUSINESS FRIENDLY---ASSUMPTON: YOU CURRENTLY EMPLOY ASSUMPTON: YOU CURRENTLY EMPLOY “WRITINGS” WITH YOUR CUSTOMERS)“WRITINGS” WITH YOUR CUSTOMERS)

QUOTATION SHEETS, PROPOSALS, BOOKING QUOTATION SHEETS, PROPOSALS, BOOKING CONFIRMATIONS, SPECIAL TEMPLATE, E-CONFIRMATIONS, SPECIAL TEMPLATE, E-MAILSMAILS

MORE THAN ONE “WRITING” O.K.---”TIE” MORE THAN ONE “WRITING” O.K.---”TIE” THEM TOGETHERTHEM TOGETHER

WHY BILL OF LADING WHY BILL OF LADING MAY NOT BE ANMAY NOT BE AN NRA NRA NOTICENOTICE

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WHAT IS A WRITING? continuedWHAT IS A WRITING? continued• SAMPLE NRA NOTICE ON “WRITINGS”:SAMPLE NRA NOTICE ON “WRITINGS”:“ “ Carrier has opted to be exempt from tariff publication Carrier has opted to be exempt from tariff publication

requirements per 46 C.F.R. §520 and 532. In that respect Carrier requirements per 46 C.F.R. §520 and 532. In that respect Carrier has opted for exclusive use of Negotiated Rate Arrangements has opted for exclusive use of Negotiated Rate Arrangements (“NRAs”).(“NRAs”). The writings provided in The writings provided in Carrier’s Carrier’s _(name _(name documents)_documents)_and and e-mail exchanges between the Carrier and the e-mail exchanges between the Carrier and the shipper cumulatively contain an offer(s) by Carrier pursuant to shipper cumulatively contain an offer(s) by Carrier pursuant to 46CFR§532.6. Acceptance of the quotation shall become binding 46CFR§532.6. Acceptance of the quotation shall become binding after receipt of the cargo by the carrier or its agent (or the after receipt of the cargo by the carrier or its agent (or the originating carrier in the case of through transportation). If the originating carrier in the case of through transportation). If the terms and conditions contained in the aforementioned documents terms and conditions contained in the aforementioned documents do not reflect Shipper’s understanding, Shipper must notify Carrier do not reflect Shipper’s understanding, Shipper must notify Carrier immediately. Carrier Rules tariff, provided free of charge at immediately. Carrier Rules tariff, provided free of charge at www.NVOCC.com, , contains the terms and conditions which are contains the terms and conditions which are further applicable to this shipment. Carrier reserves the right to further applicable to this shipment. Carrier reserves the right to modify its NRA rate/charges offer prior to Carrier or its agent modify its NRA rate/charges offer prior to Carrier or its agent (including originating carriers in the case of through (including originating carriers in the case of through transportation) receiving the cargo for transport. “transportation) receiving the cargo for transport. “

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WHAT IS A BINDING WHAT IS A BINDING ARRANGEMENT?ARRANGEMENT?• THE ELELMENTS OF A CONTRACT THE ELELMENTS OF A CONTRACT (:”BINDING (:”BINDING

ARRANGEMENT”)ARRANGEMENT”)

**AN OFFER-AN OFFER---THE WRITTEN EXCHANGES --THE WRITTEN EXCHANGES FROM THE FROM THE NVOCC NEED TO BE CLEAR WHAT SERVICE NVOCC NEED TO BE CLEAR WHAT SERVICE AND AND RATES/CHARGES IT IS OFFERING TO ITS RATES/CHARGES IT IS OFFERING TO ITS CUSTOMERCUSTOMER

* * ACCEPTANCEACCEPTANCE---THE RESPONSE FROM THE ---THE RESPONSE FROM THE SHIPPER SHIPPER MUST BE CLEAR THAT IT ACCEPTS MUST BE CLEAR THAT IT ACCEPTS THE THE OFFER; OFFER; BUT BUT IT IS ONLY THE CARRIER “RECEIVING” IT IS ONLY THE CARRIER “RECEIVING” THE CARGO THE CARGO THAT LEGALLY BINDS THE PARTIES.THAT LEGALLY BINDS THE PARTIES.

* * CONSIDERATONCONSIDERATON---USUALLY THE PROMISE OF ---USUALLY THE PROMISE OF RATES RATES AND CHARGES BY THE NVOCC AND THE AND CHARGES BY THE NVOCC AND THE PROMISE TO PROMISE TO PAY BY THE SHIPPER ARE PAY BY THE SHIPPER ARE SUFFICIENT SUFFICIENT CONSIDERATION + TENERING THE CARGO.CONSIDERATION + TENERING THE CARGO.

NVOCC BEST PRACTICESNVOCC BEST PRACTICES: DEVELOP : DEVELOP STANDARDIZED STANDARDIZED CLEAR LANGUAGE FOR QUOTES, E-CLEAR LANGUAGE FOR QUOTES, E-MAIL OR OTHER MAIL OR OTHER TRANSMISSION OF AN OFFER; TRANSMISSION OF AN OFFER; BINDINGBINDING DOES NOT DOES NOT REQUIRE SIGNATURESREQUIRE SIGNATURES

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WHAT IS A BINDING WHAT IS A BINDING ARRANGEMENT?ARRANGEMENT?• CONTRACT REQUIREMENTS: CONTRACT REQUIREMENTS: DISCUSSION DISCUSSION

POINTSPOINTS

1. IS AN NRA A “PROMISE FOR A PROMISE”?1. IS AN NRA A “PROMISE FOR A PROMISE”?

If yes, then it is binding when the If yes, then it is binding when the NVO NVO offers the rate offers the rate and the and the shipper “accepts” the shipper “accepts” the offer offer with a writing (e-mail, etc.).with a writing (e-mail, etc.).

OROR

2.2.IS AN NRA A “PROMISE FOR AN ACT”?IS AN NRA A “PROMISE FOR AN ACT”?

If yes, then it is binding when If yes, then it is binding when the NVO (or the NVO (or agent) receives the cargo.agent) receives the cargo.

3.3.TEST: TEST: IF THE BINDING OCCURS AS PER 1, IS IF THE BINDING OCCURS AS PER 1, IS THE SHIPPER THE SHIPPER OBLIGATED TO SHIP ANYTHINGOBLIGATED TO SHIP ANYTHING??

TEST: TEST: IF THE SHIPPER TENDERS NO CARGO, IS IF THE SHIPPER TENDERS NO CARGO, IS THE NVO OBLIGATED TO KEEP THE RATE THE NVO OBLIGATED TO KEEP THE RATE OPEN?OPEN? 1010

PERMISSILBE ELEMENTS OF AN NRAPERMISSILBE ELEMENTS OF AN NRA

• BASE FREIGHT RATEBASE FREIGHT RATE

• ““ALL-IN” FREIGHT RATE (WITH ALL CHARGES)ALL-IN” FREIGHT RATE (WITH ALL CHARGES)

• BASE RATE SPECIFYING WHICH CHARGES INCLUDEDBASE RATE SPECIFYING WHICH CHARGES INCLUDED

• IF OTHER CHARGES APPLY, MUST SPECIFY BY IF OTHER CHARGES APPLY, MUST SPECIFY BY REFERENCE TO CHARGES IN NRA AND/OR RULES REFERENCE TO CHARGES IN NRA AND/OR RULES TARIFFTARIFF

• NO ABILITY TO PROVIDE “GRI”NO ABILITY TO PROVIDE “GRI”

• CANNOT INCLUDE VOLUME COMMITMENT, MQC, CANNOT INCLUDE VOLUME COMMITMENT, MQC, LIQUIDATED DAMAGES, FORUM SELECTION CLAUSES, LIQUIDATED DAMAGES, FORUM SELECTION CLAUSES, OTHER CONTRACT ELEMENTS (MUST USE NSAs); (OR OTHER CONTRACT ELEMENTS (MUST USE NSAs); (OR RULES TARIFF?)RULES TARIFF?)

• NAMES AND ADDRESSES OF PARTIES MUST BE NAMES AND ADDRESSES OF PARTIES MUST BE INCLUDED; AFFILIATES OF SHIPPERS ELIGIBLE TO INCLUDED; AFFILIATES OF SHIPPERS ELIGIBLE TO SHIP MUST BE IDENTIFIED BY NAME AND ADDRESSSHIP MUST BE IDENTIFIED BY NAME AND ADDRESS 1111

WHAT IS AN “ELIGIBLE NVOCC”? WHAT IS AN “ELIGIBLE NVOCC”?

• FMCFMC REGULATION: APPLIES REGULATION: APPLIES ONLYONLY TO TO LICENSEDLICENSED NVOCCs NVOCCs

• REGISTERED NVOCC OPTIONS:REGISTERED NVOCC OPTIONS:

** A.A. If U.S. Affiliate is Licensed If U.S. Affiliate is Licensed Forwarder, Forwarder, add NVO Function by FMC add NVO Function by FMC ApplicationApplication

** B.B. Register Foreign Company to do Register Foreign Company to do Business Business in U.S. State and Apply for in U.S. State and Apply for FMC NVOCC FMC NVOCC License (this company can License (this company can be qualified be qualified with foreign officer with foreign officer experience or U.S. experience or U.S. affiliate QI holding affiliate QI holding Forwarder License.Forwarder License.

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““Negotiated Rate Arrangements Negotiated Rate Arrangements Key RequirementsKey Requirements

• NRA MUST BE IN PLACE NRA MUST BE IN PLACE PRIOR TO CARGO BEING PRIOR TO CARGO BEING RECEIVEDRECEIVED BY OCEAN CARRIER OR MOTOR BY OCEAN CARRIER OR MOTOR CARRIER IF THROUGH BILL IS ISSUED BY NVOCCCARRIER IF THROUGH BILL IS ISSUED BY NVOCC

DISCUSSION POINTS: DISCUSSION POINTS: ABOVE ALLOWS NVOCC ABOVE ALLOWS NVOCC TO ENTER NEW NRA IF MARKET PLACE TO ENTER NEW NRA IF MARKET PLACE CHANGES: RATES/CHARGES CHANGES: RATES/CHARGES !!! NEW WRITING. !!! NEW WRITING. EVERY SHIPMENT TRANSACTION AN NRA? EVERY SHIPMENT TRANSACTION AN NRA? WHAT DOES 30 DAY MODEL DO?WHAT DOES 30 DAY MODEL DO?

• PRIOR TO NVOCC ENTERING NRA: A) MUST PRIOR TO NVOCC ENTERING NRA: A) MUST PROVIDE SHIPPER PROVIDE SHIPPER WITH TERMS IN RULES WITH TERMS IN RULES TARIFF TARIFF OROR B) PROVIDE B) PROVIDE ELECTRONIC ACCESS ELECTRONIC ACCESS TO TO RULES TARIFF (FREE OF CHARGE)RULES TARIFF (FREE OF CHARGE)

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““Negotiated Rate Arrangements Negotiated Rate Arrangements Miscellaneous RequirementsMiscellaneous Requirements

DISCUSSION POINTDISCUSSION POINT

• RATES RATES SHALL NOT BE MODIFIED SHALL NOT BE MODIFIED AFTER AFTER THE TIME THE SHIPMENT IS RECEIVED THE TIME THE SHIPMENT IS RECEIVED BY THE CARRIER OR ITS AGENT BY THE CARRIER OR ITS AGENT ((INCLUDING ORIGINATING CARRIERS IN INCLUDING ORIGINATING CARRIERS IN THE CASE OF THROUGH THE CASE OF THROUGH TRANSPORTATION).TRANSPORTATION).

• Parties can mutually terminate NRA Parties can mutually terminate NRA BEFORE CARGO IS RECEIVED BEFORE CARGO IS RECEIVED and enter and enter new NRA?new NRA?

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NEW NVOCC BIBLE: RULES NEW NVOCC BIBLE: RULES TARIFFS---WHAT TO PUT IN THEM?TARIFFS---WHAT TO PUT IN THEM?

• ““RULES TARIFF” RULES TARIFF” ((as defined by 46 CFR 520.2), as defined by 46 CFR 520.2), CONTAINS TERMS AND CONDITIONS CONTAINS TERMS AND CONDITIONS GOVERNING GOVERNING CHARGES,CHARGES, CLASSIFICATION, CLASSIFICATION, RULES, REGULATIONS AND PRACTICES OF RULES, REGULATIONS AND PRACTICES OF AN NVOCC (DOES NOT INCLUDE RATES). AN NVOCC (DOES NOT INCLUDE RATES).

• REMEMBER: TARIFF RULES REMEMBER: TARIFF RULES HAVE THE HAVE THE EFFECT OF LAWEFFECT OF LAW ON PRIVATE ON PRIVATE TRANSACTIONS.TRANSACTIONS.

• COURTS WILL IMPUTE COURTS WILL IMPUTE CONSRUCTIVE CONSRUCTIVE KNOWLEDGEKNOWLEDGE TO SHIPPER PARTIES OF RULES TO SHIPPER PARTIES OF RULES IN TARIFFSIN TARIFFS

• CHOOSE TARIFF RULES LANGUAGE WISELYCHOOSE TARIFF RULES LANGUAGE WISELY 1515

RULES TARIFFS---WHAT TO PUT IN RULES TARIFFS---WHAT TO PUT IN THEM? DISCUSSION POINTS:THEM? DISCUSSION POINTS:

• CHARGES----CHARGES----CARE SHOULD BE TAKEN IN CARE SHOULD BE TAKEN IN COORDINATING NRA LANGUAGE & RULES TARIFFCOORDINATING NRA LANGUAGE & RULES TARIFF

• WHAT ABOUT CARRIER RATE INCREASES, GRI’s, WHAT ABOUT CARRIER RATE INCREASES, GRI’s, PSS, BAF’s ETC. ?PSS, BAF’s ETC. ?

• OTHER RULE ITEMS:OTHER RULE ITEMS:

** GENERAL LIEN LANGUAGEGENERAL LIEN LANGUAGE

** ABANDONEMENT ABANDONEMENT

** WAREHOUSEMEN LANGUAGEWAREHOUSEMEN LANGUAGE

** DEMURRAGE, DETENTION, PER DEMURRAGE, DETENTION, PER DIEM RESPONSIBILITY---PASS DIEM RESPONSIBILITY---PASS

THROUGH LANGUAGE SHOULD BE THROUGH LANGUAGE SHOULD BE CLEARCLEAR

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Recordkeeping and Audit Recordkeeping and Audit

• NVOCC MUST MAINTAIN ORIGINAL NRA’s AND NVOCC MUST MAINTAIN ORIGINAL NRA’s AND ASSOCIATED RECORDS, INCLUDING WRITTEN ASSOCIATED RECORDS, INCLUDING WRITTEN COMMUNICATIONS COMMUNICATIONS FOR 5 YEARS.FOR 5 YEARS.

• NRA’s MUST BE KEPT IN A FORMAT WHICH CAN BE NRA’s MUST BE KEPT IN A FORMAT WHICH CAN BE PRODUCED PROMPTLY TO FMC PRODUCED PROMPTLY TO FMC UPON REQUEST. UPON REQUEST.

  

• FAILURE TO KEEP FAILURE TO KEEP OR OR TIMELY PRODUCE TIMELY PRODUCE ORIGINAL ORIGINAL NRA’s WILL DISQUALIFY NVOCC FROM EXEMPTION NRA’s WILL DISQUALIFY NVOCC FROM EXEMPTION AND MAY RESULT IN AND MAY RESULT IN SHIPPING ACT VIOLATIONS SHIPPING ACT VIOLATIONS FOR NON-PUBLISHING OF RATES AND RELATED FOR NON-PUBLISHING OF RATES AND RELATED PRACTICES. PRACTICES.

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ROLE OF TARIFF PUBLISHER ROLE OF TARIFF PUBLISHER REVISITEDREVISITED

• PRIOR TARIFF MATERIAL NEEDS TO BE PRIOR TARIFF MATERIAL NEEDS TO BE MAINTAINED ELECTRONCIALLY FOR 5 MAINTAINED ELECTRONCIALLY FOR 5 YEARS, THE YEARS, THE LAST 2 YEARS MUST BE LAST 2 YEARS MUST BE RETRIEVABLE ON-LINE RETRIEVABLE ON-LINE

• COORDINATION OF COORDINATION OF EFFECTIVE DATES OF EFFECTIVE DATES OF CHARGES IN ALL TRADE LANES REQUIRED CHARGES IN ALL TRADE LANES REQUIRED FOR ACCURATE PRICE QUOTATIONS (NRAs). FOR ACCURATE PRICE QUOTATIONS (NRAs). COMMERCIAL QUESTION; NOT LEGAL.COMMERCIAL QUESTION; NOT LEGAL.

• SHOULD NVOCC MAINTAIN ITS OWN DATA SHOULD NVOCC MAINTAIN ITS OWN DATA BASE WITH CURRENT CHARGES FOR ALL BASE WITH CURRENT CHARGES FOR ALL TRADE LANES, OR IS THIS FUNCTION FOR TRADE LANES, OR IS THIS FUNCTION FOR OUTSIDE VENDOR? OUTSIDE VENDOR? COMMERCIAL QUESTION; COMMERCIAL QUESTION; NOT LEGAL.NOT LEGAL.

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