No. The ISF must be submitted at the lowest bill of lading level (i.e., house bill or regular bill) that is transmitted into ACE. If the carrier creates and transmits a regular bill of lading number on behalf of a non-automated NVOCC or freight forwarder, the ISF filer must submit the regular bill of lading number that was transmitted into ACE as part of the ISF. A master bill of lading will always have underlying house bills.

Valid qualifier codes are:
OB (ocean bill of lading – used for regular bills),
BM (house bill of lading)

For purposes of the ISF, the following bill of lading definitions apply:

Regular Bill – a standalone bill of lading that is not associated with any underlying house bills. It is also known as a straight bill or simple bill, and it is the bill that is reported to the US Customs and Border Protection (CBP) in the Automated Commercial Environment (ACE). If there are multiple regular bills, each one will be reported in a separate SF15 record.

House Bill – a Bill of lading that is issued under a master bill. It is reported to the CBP in ACE, and if there are multiple house bills, each one will be reported in a separate SF15 record.

Master Bill – a bill of lading that covers one or more underlying house bills of lading. The filer has the option to provide the master bill number in an SF20 record with an MB qualifier. If there are multiple master bills, each one will be reported in a separate SF20 record.

It is important to note that the CBP only requires the number for the regular bill or house bill to be reported in an ISF, and not the master bill number. CBP requires only the number for the bill of lading at the lowest level (i.e., the regular straight/simple bill of lading or house bill of lading) and not the master bill of lading number to be reported in an ISF.