In CBP’s FAQ dated 07/09/10, pages 51-52 contained a provision to allow this for Late ISF Filings or cargo that arrived in the U.S. with no ISF. CBP indicates this option is still valid even though the FAQ date of 6/30/11 has expired. 

The trade community should note that 19CFR149.5 does state “bond required” for an ISF to be eligible under the regulations. We caution the trade in using the ISF Submission Type 5 “Late ISF 10 – No Bond” unless CBP approves its usage. CBP’s legal department is still reviewing the matter and should be noted that ISF with “No Bond” will be subject to a non-intrusive inspection (NII) and other delays and expense in releasing the cargo. Plus CBP does not want the “No Bond” option abused, and it should be limited to one-time importers. 

CBP FAQ’s dated 7/9/10 can be found at the following link and excerpt from the FAQ is provided below along with relevant regulation: http://www.cbp.gov/linkhandler/cgov/trade/cargo_security/carriers/security_filing/10_2faq.ctt/10_2faq.doc