For years, companies and service providers have arranged transportation and not given a second thought to the relevant regulatory scheme for property brokers. While the obligation to qualify as a property broker has been on the books since at least 1988, in the absence of enforcement, many parties provide the service of arranging transportation for compensation, but are not property brokers. That is all about to change when the MAP-21 regulations become effective on October 1, 2013. If you are arranging the transportation of goods in interstate commerce (so across state lines or into or out of the U.S.), you would be wise to look carefully at how MAP-21 impacts your business. While customs brokers and freight forwarders are the ones most directly impacted, companies that arrange these services for sister entities must also be careful to navigate the new law and implementing regulations. While MAP-21 itself took effect on October 1, 2012, the final implementing regulations are not yet on the books, but are expected to be in place by the October 1, 2013, enforcement deadline.
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