Friday, November 20, 2009

CSAT FAQ #1649

For the last year or so I have typically been reporting on new and updated DHS CSAT Frequently Asked Question (FAQ) on a weekly basis. These are not usually urgent and it takes up too much time and effort to report on each and every FAQ change as it is posted. I do, however, review them every morning because from time to time one comes up that may appear to require quicker reporting. Yesterday, DHS posted such a new FAQ: 1649 How do I request an extension of my facility’s Top-Screen, SVA or SSP filing deadline? Actually, the question does not appear to time critical, but the response indicates a potential problem with DHS receiving these requests. The response states: “A request for an extension must be submitted to DHS in writing by USPS or delivery service. DO NOT FAX your extension request to the CSAT Help Desk.” The emphasis was added by DHS, not here at the blog. I can think of a number of legal reasons that DHS might require an original document with signature, but I also know, from long experience, that things sent by fax to not always get to the recipient in a timely manner or they get garbled in transmission. BTW: CVI rules do allow for transmission of CVI by fax, but they do require prior coordination with the receiver to ensure that a CVI authorized user with need to know is on the receiving end of the fax transmission to ensure that appropriate security measures are put into place to protect the document upon its receipt. In any case; when DHS shouts at us with CAPS in their fax, I assume that they are especially concerned that the message is important. So please, do not fax your extension requests to the CSAT Help Desk.

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