PSC Before CAPE: Do You Need It to Route Refunds to a Broker via Box 28?
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TL;DR — If your broker was never added as a notify party on Box 28 of the original entry, a PSC is the clean way to fix that — but only before CAPE is accepted. Once CAPE processes your entries, PSC is permanently blocked. If you're FIOR, the refund goes to you as IOR automatically. If the importer has no US bank account and no Box 28 designation, the refund will be held until ACH enrollment is in place.
The Question Most Brokers Are Asking Right Now
You filed CAPE for a foreign importer with no US bank account. You want the refund routed to your broker account. CBP's guidance says this works — but only if the broker is designated as a notify party on the entry (Box 28 of CF-7501) and has ACH refund enrollment in ACE.
Most brokers never added themselves to Box 28 on original entries. That's the real problem. And it's why the question of whether to file a PSC before CAPE is anything but theoretical.
What Box 28 Is and Why It Matters
Box 28 on CBP Form 7501 (Entry Summary) is the "Reference Number" field — it's where the notify party's importer of record number appears when a Form 4811 (Special Address Notification) has been filed on that entry.
CBP's official position on refund routing is specific: refunds go to the IOR, or to a party designated via CBP Form 4811 or ACE Portal — and who is listed on the entry summary. Both conditions must be met. A Form 4811 or ACE Portal designation alone, without the corresponding Box 28 notation on the entry, puts you in a gray area.
This is confirmed in CSMS #67648307, which updated Form 4811 procedures effective February 6, 2026.
If the Broker Was Never on Box 28
This is the situation most brokers are in right now. Two paths exist before CAPE:
PSC to update Box 28. A Post Summary Correction adds the broker as notify party on the original entry, which then appears in Box 28. Once CBP processes the PSC, the entry reflects the correct designee before CAPE runs. This is the clean path that matches CBP's official guidance.
ACE Portal designation only. CBP added a feature allowing notify party designation directly through the ACE Portal, without filing a paper Form 4811. According to CBP, this can work — but whether it fully satisfies the "on the entry summary" requirement where no PSC was filed is a question that hasn't been definitively answered in official guidance. In practice, the PSC route gives you the cleaner paper trail.
The window for either approach closes when CAPE is accepted. After that, PSC is blocked permanently.
After CAPE: PSC Is Locked
Once a CAPE Declaration is accepted, Post Summary Corrections are permanently blocked on those entries. Any PSC attempt returns Error Code 864 — "PSC NOT ALLOWED — REFUND REQUESTED".
If the refund is issued and then rejected by the bank (wrong account, no ACH enrollment), there is a separate Replacement Refund process on CBP.gov. But it requires the importer's Trade Account Owner to initiate, and it takes additional time. The PSC-before-CAPE approach avoids this entirely.
FIOR Situations
If the broker filed as the Filer as IOR — meaning the broker is the importer of record on the original entry — the refund goes directly to the broker as IOR. No notify party designation, no PSC, no Box 28 update needed. Just confirm the broker's ACE account has ACH refund bank information enrolled.
Non-Portal Importers
For importers without an ACE Portal account, CBP holds the refund until ACH enrollment is completed. The importer needs an ACE Portal Importer sub-account with the ACH Refund Authorization tab filled out. Alternatively, a broker designated as 4811 notify party (on the entry and with ACH enrollment) receives the refund on their behalf.
Note: the bank account in the importer's ACH Refund tab should be the importer's own account. Putting the broker's bank account in the importer's ACH tab is a workaround some firms are using — CBP doesn't appear to cross-check account ownership technically — but it sits outside the official guidance in CSMS #67648307 and carries compliance risk if refunds are ever audited.
What to Do Before Filing CAPE
Check whether your broker is listed as notify party on Box 28 of the entries you plan to include. If not, and you want refunds routed to the broker, file a PSC now — before submitting CAPE. After CAPE acceptance, that door closes permanently.
If you're FIOR, verify your ACE account has ACH refund enrollment. If the importer is non-portal with no US bank account, sort out either the PSC path or the ACE Portal designation before CAPE — not after.
Frequently Asked Questions
Is a PSC required before CAPE to route refunds to a broker? Not always — but if the broker was never listed as notify party on Box 28 of the original entry, a PSC is the clean official path to set that up before CAPE. ACE Portal designation exists as an alternative, but the "on the entry summary" condition in CBP's guidance makes the PSC route more straightforward. After CAPE acceptance, neither is possible.
What is Box 28 on CF-7501? It's the "Reference Number" field where the notify party's IOR number appears when a Form 4811 has been filed on the entry. CBP uses this to determine who receives refunds when the IOR has designated a third party.
Can I file a PSC after CAPE to fix routing? No. Once CAPE is accepted, PSC is permanently blocked (Error Code 864). If the refund is issued and rejected, the Replacement Refund process on CBP.gov is the remaining path — but it requires the importer's Trade Account Owner to initiate.
What is FIOR and how does it affect refund routing? FIOR stands for Filer as IOR — the broker is the importer of record on the entry. In this case, refunds go directly to the broker as IOR. No notify party designation or PSC is needed.
What if the importer has no US bank account? CBP will hold the refund until ACH enrollment is completed in ACE. The importer must set up an ACE Portal Importer sub-account with ACH Refund Authorization, or the broker can receive the refund via Form 4811 if properly designated on the entry with their own ACH enrollment.
Does the ACE Portal designation replace Form 4811? CBP added ACE Portal designation as an alternative to filing a paper Form 4811. Both are referenced in CBP's guidance. However, the requirement to also be listed "on the entry summary" means entries where no designation was ever made may still need a PSC to be fully compliant.