Legal

CBSA Record Custodian Service Terms

Last updated October 28, 2026

Last updated 26 October 2026

These terms apply when you buy the CBSA Record Custodian Service online at jonescosman.com. They sit alongside the custodian engagement letter you receive after payment. If the two ever conflict, the signed engagement letter governs.

1. Who you are dealing with

Ecommerce Accounting Services Ltd., operating as Jones & Cosman CPA, 431 Euclid Avenue, Toronto, Ontario M6G 2T1, Canada, is the party to your engagement letter and the records custodian named on your Form BSF900 (“we”, “us”, “the Firm”).

Online payments are processed by JCCPA LLC, an affiliated company, through Stripe. Your card statement, Stripe receipts and invoices show JCCPA LLC. JCCPA LLC collects the fee on behalf of Ecommerce Accounting Services Ltd. and provides no services to you itself.

“Company” in these terms includes a sole proprietorship or a partnership where that is the business buying the service; “signing officers” then means the owner, or the signing partners.

2. What the service includes

  • Preparation of Form BSF900, Agreement to Maintain Records Elsewhere Than the Place of Business in Canada, naming our Toronto office as the place where your import books and records are kept, with the server section completed for Canadian-hosted storage.
  • A custodian engagement letter signed by the Firm, for your signing officers to countersign and upload in the CARM Client Portal together with the BSF900.
  • A private, encrypted folder for your company on servers located in Canada, with access restricted to you and authorised Firm personnel.
  • Retention of the records you upload for six years following the end of the calendar year in which the goods were imported, while the account is in good standing.
  • Responding to reasonable requests from the Canada Border Services Agency for the records we hold, and producing them in Canada when required.
  • Guides for completing your CARM Client Portal registration, answering the books and records question, and uploading the custodian package.

You keep using whatever courier, freight forwarder or customs broker you choose. Nothing in this service changes who clears your shipments.

3. What the service does not include

Customs brokerage or clearance, payment of duties or taxes, GST/HST registration or returns, provincial sales tax, bookkeeping, historical reconciliations, and representation during a CBSA verification or audit are not included. Any of these can be quoted separately. Whether CBSA accepts your BSF900 is CBSA’s decision; we prepare the form to current CBSA requirements but do not control the approval.

4. Fees, renewal and refunds

  • The fee is US$999 per year, billed annually in advance by card in US dollars at the time of purchase.
  • If you add the optional business number and import account registration, a one-time fee of US$499 is charged together with your first payment. It covers preparing and filing the Canadian business number and RM import-export account application with the CRA on your behalf and handling the CRA correspondence for that registration; GST/HST registration is included at no extra charge where you ask for it. It does not renew. Issuing the accounts is the CRA’s decision and timeline, not ours.
  • The subscription renews automatically on each anniversary of your purchase at the then-current annual fee. Stripe emails you before the renewal date. You can stop the renewal at any time from your billing portal; the service then continues to the end of the paid year.
  • Any change to the annual fee is communicated in writing at least sixty days before it takes effect.
  • All fees are non-refundable once paid, including where you cancel part-way through a paid year or CBSA does not approve your BSF900 for reasons outside our control.

5. Non-payment

If a renewal payment fails, Stripe retries the card and emails you. If the renewal remains unpaid thirty days after it was due, access to your records folder is suspended; the records themselves are kept intact during a suspension. Fees outstanding more than thirty days end the service, and we notify CBSA that we no longer act as your records custodian.

6. Your responsibilities

  • Give us accurate, complete information on the signup form. It goes directly onto your BSF900 and engagement letter.
  • Upload the company documents we ask for after payment: certificate of incorporation or a current registry extract, proof of good standing dated within the last three months, government photo identification for each signing officer, and a director or shareholder register where the extract does not list the directors.
  • Have your officers sign the BSF900 and the engagement letter, and upload them in your CARM Client Portal together with your registry extract and proof of good standing.
  • Upload your import documentation (commercial invoices, packing lists, customs accounting documents, duty and tax receipts, permits and certificates) within the timeframes set out in the client upload guide, and keep it flowing for every shipment.
  • Tell us within thirty days if your business address, contact details, officers or customs broker change.

Records that are missing or late because documents were not uploaded are your responsibility, and the Firm is not liable for penalties that result from incomplete or late submissions.

7. Cancellation and termination

Either party may end the engagement on thirty days’ written notice. On termination you have thirty days to transfer your records to another authorised custodian; after that, access to the folder is suspended. If we receive no transfer instructions, the records are archived securely for twelve months and may then be deleted. Requests to retrieve records after the thirty-day transition period are charged separately. Our custodial obligation ends once the records are transferred or destroyed under this section.

8. Confidentiality and data

Your records are stored encrypted on servers physically located in Canada. Access is restricted to you and authorised Firm personnel, and we follow the confidentiality standards that apply to CBSA and CRA information. Identification documents you upload are used only to verify the company and its officers for this engagement. Our privacy policy explains how we handle personal information, including payment data processed by Stripe.

9. Limitation of liability

The Firm is not responsible for penalties, interest or losses resulting from inaccurate information you provide, late uploads, CBSA decisions, or system access delays beyond our control. Our total liability under this engagement is limited to the fees paid for the year in which the claim arises.

10. General

These terms and the engagement letter are governed by the laws of Ontario and the federal laws of Canada applicable in Ontario. Your acceptance of these terms during checkout, recorded with a timestamp, forms part of our engagement records. Questions about the service go to [email protected].