Raymond Kelly, the commissioner of Customs, isn't reticent when it comes to the problems he inherited when he took over the agency in August 1998.

He paints a picture of an agency in serious disarray: unclear lines of command, inconsistent hiring and discipline policies, nonexistent training, perceptions of favoritism, and a poor image on Capitol Hill and with the public as a result of negative news stories, including an infamous series in the Miami Herald.Kelly mentioned several of those issues during an interview last week with our editors and reporters, but he said it even better before the Senate Finance Committee in May:

''Instead of informed, consistent and ser- vicewide policy-making emanating from Washington headquarters, I found that inconsistent, often-uninformed decisions were being made out of hundreds of ports across the country. Decision-making on hiring, promotion, and disciplinary issues differed from one region to the next, without headquarters oversight.''

He went on: ''All of this conspired to fuel fear among the rank and file that favoritism, real or perceived, dictated who was promoted, or worse, who was protected from disciplinary action. Instead of a robust Office of Internal Affairs to combat corruption, a poorly led shell of a function existed that was further emasculated by lack of resources and authority.

''Clearly, actions had to be taken,'' Kelly said then. He repeated that conclusion to us in describing his top-to-bottom overhaul of the 19,000-employee agency.

But when asked whether the condition in which he found the agency reflected poorly on the people who preceded him as commissioner, Kelly would not say.

''I think he did a great job,'' Kelly said of his immediate predecessor, George Weise. ''He had to deal with the agency as he found it. He had other things on his mind,'' such as implementing the Customs Modernization Act of 1993.

Putting aside whether it's possible to praise someone who led an organization described in such terms, let's consider the bigger picture. Kelly's praise of Weise illustrates the non-confrontational and inclusive way in which the former New York City police commissioner and Marine colonel is approaching his current job.

Kelly appears determined to dispel once and for all any lingering perception that, because he's a former cop who came to the Customs job largely on his enforcement credentials, he's another William von Raab. Importers and customs brokers still shudder at the memory of von Raab's tenure as commissioner in the mid-1980s. The heavy-handed official managed to antagonize virtually the entire trade community.

After the more productive terms of his successors - including Weise, a saint to the trade community who helped shepherd the Customs Modernization Act through Congress - the prospect of anyone who resembled von Raab wasn't a good one.

Happily for the trade community, those fears haven't been borne out.

Whether he hears it in the daily briefings from his trade ombudsmen or when he's out in the field, Kelly is absorbing what importers and customs brokers are telling him. There's ample evidence by now that he is listening to the trade community, and responding.

Three recent issues of importance to the trade illustrate this.

The first was Kelly's response to complaints from importers last fall that compliance-assessment audits were taking too long, costing importers too much in time and resources and unfairly branding law-abiding companies as scofflaws.

Instead of discounting importers' complaints, as the agency might have done in the past, Customs under Kelly wasted no time. It looked inward. Yes, the agency responded, the audit process isn't perfect. Improvements are on the way.

The second was Kelly's response to the lack of funds appropriated to continue a pilot program of Customs' next-generation computer system, called the National Customs Automation Prototype.

Kelly has made many statements indicating he understands the need for a new customs computer system to replace the obsolete and overloaded Automated Commercial System. But faced with the reality of having to shut down the prototype, he did more than talk. He worked with his former colleagues at the Treasury Department to locate $3 million in unbudgeted funds. (Kelly was undersecretary for enforcement at Treasury for two years prior to becoming Customs commissioner.)

Finally, as Bill Mongelluzzo and Jack Lucentini have been reporting this week, a major breakthrough has apparently been achieved to replace the antiquated, entry-by-entry system for filing documents and paying duties with a new credit card-like system.

Nothing except perhaps the new computer system is higher on importers' and brokers' wish list for changes at Customs. If this development is for real - and early indications are that it is - it looks as if consensus may exist to pass the first piece of major customs legislation since 1993. And it happened remarkably fast, without the endless negotiations and posturing that preceded the Modernization Act.

The trade community, to be sure, played a key role in bringing this about by putting aside internal differences and agreeing to speak with one voice - no insignificant accomplishment.

But Customs, and Kelly in particular, deserve credit as well for an attitude that is open to dialogue and respectful of a key constituency.

As Kelly made clear on several occasions during our interview, the legacy of open communication between Customs and the trade is one of the greatest assets the agency has, and one he intends to carry on.

''This communication culture has existed for a long while,'' he said. ''I champion this communication. It's working.''