01Problem
Interstate household-goods shippers face bait-and-switch pricing and, at the extreme, hostage loads. FMCSA does not resolve individual claims or recover goods. USMPO/Trunk aggregations of FMCSA’s public HHG lookup put 2025 complaints near 4,480 (not an official FMCSA annual total). DOT OIG (October 6, 2025): Abda Moving / 11 Even Movers sentenced; restitution $1,908,486. 49 CFR Part 375 supplies the 110% rule, Full Value Protection default, and 3-day BOL cooling-off.
02Intake
- Origin and destination addresses (interstate vs intrastate vs commercial zone); load date; COD vs prepaid.
- Company legal name, USDOT, MC; whether it claims carrier or broker; written estimate (binding vs non-binding) and survey (on-site or virtual).
- Ready to Move brochure and Rights and Responsibilities booklet (or signed hyperlink receipt).
- Bill of lading, inventory, valuation statement (FVP vs Released Value waiver), high-value article list (>$100/lb).
- Form of payment specified on the estimate; any blank document the shipper was asked to sign.
- Pickup/delivery dates or windows; accessorials (stairs, long carry, shuttle, SIT).
- Photos of tendered payment and of any extra demand at the truck; BOL number for a hostage complaint.
03Playbook
- 01
Lookup before a deposit. HHG search (https://ai.fmcsa.dot.gov/hhg/search.asp) for authority type and four-year complaint table; SAFER snapshot; SMS. Motus L&I filing sunset May 14, 2026. Good = active HHG carrier, insurance and cargo on file, BOC-3, trucks in the census, complaints small vs fleet. Bad = broker-only advertising as a mover, new DOT number, zero trucks, high Estimates/Hostage counts. A motor carrier may not broker unless separately registered (49 U.S.C. 13902(a)(6)). SAFER fields: Entity Type Carrier, USDOT Active, Operating Authority Authorized for HHG.
- 02
Name the party on the estimate. FMCSA FAQ (October 8, 2026): a broker is not authorized to transport household goods. Brokers must be registered, give R&R + Ready to Move, list the movers they use, use only FMCSA-registered movers, have a written agreement, and base estimates on the mover’s tariff. If the truck’s legal name differs from the estimate, freeze and match USDOT/MC before loading.
- 03
Cargo on file is not the claim cap. 49 CFR 387.303T: HHG cargo filing $5,000 per vehicle / $10,000 per occurrence — the FMCSA minimum, separate from Carmack/FVP. Broker BMC-84/85 $75,000; 387.307 immediate-suspension procedures effective January 16, 2026. Public liability: $750,000 for vehicles ≥10,001 lb GVWR.
- 04
Written estimate after a physical survey. Physical survey includes virtual video (375.103, 2022 rule). Shipper may waive the survey in a writing signed before loading. Binding = guaranteed total for identified services. Non-binding = approximate; final charges on actual weight and tariff. “Not-to-exceed” is a Texas/CA state-tariff label, not a third federal type. Estimate may not be amended after loading. 49 CFR 375.501 is Reserved — the bill of lading is the interstate contract.
- 05
Build the inventory before the estimate. Photograph every room, garage, shed, and off-site storage. A forgotten garage of “300 cubic feet (~2,000 pounds)” is a day-of requote. List high-value articles >$100/lb in writing or FVP on those articles can be capped at $100/lb (375.201 / 375.203). Packed-by-owner cartons still must be listed (375.503). A video walkthrough feeds the inventory; it does not replace the carrier’s survey.
- 06
Honor the 110% rule at the truck. FMCSA FAQ, October 8, 2026: if you have paid 110% of the non-binding estimate or 100% of the binding estimate and the mover fails to deliver, they have violated federal HHG rules; file at complaint.fmcsa.dot.gov or 1-888-368-7238. You are not required to pay more than those caps at delivery; additional lawful charges are billed 30 days after delivery (49 CFR 375.407 / 49 U.S.C. 13707). Impracticable-operations extras ≤ 15% of other charges due at delivery. Failure to relinquish after the lawful tender is a 14915 hostage fact pattern.
- 07
Use the 3-day BOL cooling-off. 375.505(h): BOL signed and dated at least 3 days before scheduled loading; shipper may rescind without penalty for 3 days after signing. Day-of extras do not restart the 3 days. Do not sign a blank document (375.505(g)(3)).
- 08
Elect Full Value Protection unless a written waiver says otherwise. FVP is the default (49 U.S.C. 14706(f); 375.201). Released Value $0.60 per pound per article applies only after a written waiver on the STB valuation statement. Undeclared FVP minimum (STB RR 999 Amendment 5, January 12, 2012): the higher of $6.00/lb × weight or $6,000. FVP pays repair, like-kind replacement, or cash, at the carrier’s option, up to declared value. Do not apply 370.9(b) depreciation to an unwaived FVP claim.
- 09
Pay only in the form named on the estimate. FMCSA does not ban Zelle by name; the rule is that the form of payment on the estimate must be honored at delivery. A large prepaid deposit to a personal P2P account is a classic broker-scam pattern. Credit card or the carrier’s named escrow beats a cell-phone cash-app.
- 10
Hostage protocol (same day). Tender the lawful amount in the named form, photograph the tender, demand unloading, file at https://complaint.fmcsa.dot.gov/ or 1-888-368-7238 (Mon–Fri 8:00 a.m.–8:00 p.m. ET) with the BOL number. Civil penalties: STB Part 1022 $15,846/day (2025 and 2026 columns); FMCSA Part 386 Appendix B (g)(21) $20,537/day. Criminal: fine under title 18 or up to 2 years. Authority may be suspended 12–36 months. FMCSA will not pay the claim. A non-emergency police call is anecdotal; use it after the documented tender, not instead of it.
- 11
Claims calendar. Carmack 14706(e): at least 9 months from delivery to file a written claim with a specified dollar amount; at least 2 years from written disallowance to sue. Carrier ack in 30 days (370.5); pay, deny, or firm compromise in 120 days (370.9). Arbitration 14708 / 375.211: binding at $10,000 or less if the shipper requests; above $10,000 only if the carrier also agrees; decision in 60 days.
- 12
SIT conversion needs 375.609 notices at least 10 days before SIT expires (one day if SIT <10 days). Permanent storage in the shipper’s name.
- 13
Intrastate is a different code. California BHGS Maximum Rate Tariff 4 effective January 1, 2026. Florida ch. 507: written signed estimate before any service; liability floor 60 cents/lb; brokers may not estimate total move costs. Texas 43 TAC 218.56: written binding or not-to-exceed maximum before loading. New York still uses an order for service (17 NYCRR 814.3). Peak May–September is industry practice, not an FMCSA date. Commercial-zone short hauls can fall outside Part 375 (372.241).
04Checklists
Interstate mover verifier (with estimate and inventory)
- USDOT/MC looked up on ai.fmcsa.dot.gov/hhg, SAFER; carrier (not broker-only) with trucks and insurance on file
- BMC-84/85 $75,000 if a broker is in the chain; cargo filing treated as a minimum, not the claim cap
- Written estimate after physical/virtual survey; binding vs non-binding labeled on its face
- Room-by-room inventory + high-value >$100/lb list + photos
- Ready to Move + R&R booklet (or signed hyperlink receipt) in the file
- BOL signed ≥3 days before load; FVP elected or Released Value waived in writing
- Form of payment on the estimate matches what will be tendered at the truck
- 110%/binding tender amount computed; no signature on a blank document
- Hostage packet ready: BOL number, estimate, photos of tender, complaint.fmcsa.dot.gov / 1-888-368-7238
- Claim calendar: D+9 months, ack+30, pay/deny+120, suit ≥2 years from written disallowance
05Questions to ask
- Q01
“What is your USDOT and MC, and are you the household-goods carrier who will transport, or a broker?”
- Q02
“Send the written binding or non-binding estimate after a physical (on-site or virtual) survey, signed by both of us, with the form of payment honored at delivery.”
- Q03
“Confirm Full Value Protection at no less than $6.00/lb or $6,000, and that Released Value $0.60/lb/article applies only if I waive FVP in writing.”
- Q04
“What is the 110% (non-binding) or 100% (binding) amount I can tender at delivery to require you to unload?”
- Q05
“Will the bill of lading be in my hands at least three days before loading, and may I rescind in that window?”
- Q06
“List accessorials (stairs, long carry, shuttle, SIT) now; post-BOL carrier-necessary extras are billed after 30 days except impracticable operations ≤15%.”
- Q07
“Is this estimate binding, non-binding, or a state not-to-exceed, and may it be changed after loading?” (Answer must be: not after loading.)
06Red flags
Sight-unseen estimate; “we’ll price after we load”
Cash, Zelle, Cash App, or a large deposit demanded before the survey
Asked to sign blank documents
Website with no USDOT/MC
“All goods covered by our insurance” (the $5,000/$10,000 filing)
Zero-truck entity with a pile of Estimates/Hostage complaints
Broker estimate not adopted by a named carrier under 375.409/371.113
Extra demand at the curb above 110%/the binding amount as a condition of unloading
07Scripts
This is a non-binding estimate of $[E]. Under 49 CFR 375.407 and 49 U.S.C. 13707 I am tendering $[1.10 × E] — 110% — in the form of payment on the estimate. Unload my goods. Remaining lawful tariff charges are billed after 30 days. Carrier-necessary extras not on the bill of lading are not collectible now except impracticable operations up to 15%. Refusal to relinquish is a 49 U.S.C. 14915 hostage violation. I am photographing this tender and filing at complaint.fmcsa.dot.gov with bill of lading [number].
I filed FMCSA Complaint Center complaint [number] and called 1-888-368-7238. Carrier [USDOT/MC] is holding household goods under bill of lading [number] after I tendered the amount 375.407 / 13707(b)(3) allows. Demand: immediate delivery. Civil penalty $15,846/day (STB Part 1022) and $20,537/day (FMCSA Part 386 App. B (g)(21)), plus 12–36 month authority suspension. Copy: state attorney general.
Written claim under 49 U.S.C. 14706 and 49 CFR Part 370 for shipment [BOL], delivered [date]. Specified amount: $[X]. The [item, inventory ID] was [destroyed/missing]; replacement cost $[R]. This shipment moved under Full Value Protection (not Released Value). Acknowledge within 30 days (370.5) and pay, decline, or make a firm written compromise within 120 days (370.9). I request arbitration under 49 U.S.C. 14708 / 49 CFR 375.211. Suit limitation may not be less than 2 years from written disallowance.
08Tools
Callable over MCP once connected. Your agent passes the inputs and gets structured results back.
usdot_mc_mover_verifierUSDOT/MC verifier- Builds the FMCSA household-goods search and SAFER lookups for a mover and scores what you find: broker-only authority, zero power units, inactive status, or missing household-goods authority are red flags.
mover_110_percent_tender_calculator110% tender calculator- What you must pay at delivery: binding estimate → the estimate; non-binding → the lesser of actual charges or 110% of the estimate. Impracticable-operations charges at delivery are capped at 15% of that amount; the rest is billed after 30 days (49 CFR 375.407).
mover_valuation_claims_clockValuation + claims clock- Mover liability and deadlines: Released Value (signed waiver) = $0.60 per pound per article; Full Value Protection minimum valuation = greater of $6 × shipment weight or $6,000; claim due 9 months after delivery; suit at least 2 years from written disallowance.
09Formulas & rules
- Worked 110%. Non-binding estimate $4,000; actual tariff $5,200; no lawful post-BOL extras. Due at the truck = min($5,200, 1.10 × $4,000) = $4,400. Remainder $800 billed after 30 days. Impracticable-operations cap at the truck if asserted = 15% × $4,400 = $660. Refusal to unload after a documented $4,400 tender is 14915 if knowing and willful.
- Worked binding. Binding estimate $4,000. Due at the truck = $4,000 even if the truck is heavier, unless the shipper added signed services. Remainder of any lawful extra billed after 30 days.
- Worked valuation. 8,000 lb shipment; 50-lb sofa destroyed, worth $1,200. Released Value (written FVP waiver): 50 × $0.60 = $30. FVP default: min valuation = higher of 8,000 × $6.00 = $48,000 or $6,000; sofa paid up to $1,200. A 900-lb shipment uses the $6,000 floor. The $5,000/$10,000 cargo filing does not cap this claim.
- Hostage penalties: STB $15,846/day; FMCSA App. B (g)(21) $20,537/day. Unregistered HHG: STB 14901(d)(3) $49,848. Claims: file by delivery + 9 months; ack 30; pay/deny 120; suit ≥2 years from written disallowance.
10State variation
- Part 375 unamended 2024–2026. Last substantive rewrite 87 FR 24431 (April 26, 2022): virtual survey, Order for Service eliminated, 3-day BOL cooling-off. Last listed amendment 88 FR 80180 (November 17, 2023).
- Protect Your Move FAQ updated October 8, 2026 — 110%/100% hostage language confirmed live.
- Motus L&I filing sunset May 14, 2026. 387.307 broker $75,000 procedures effective January 16, 2026.
- STB 2026 inflation would have moved 14915 to $16,279; a later rule reinstated 2025 levels ($15,846) for 2026. FMCSA Appendix B updated through 91 FR 45660 (July 21, 2026).
- CA Max Rate Tariff 4 January 1, 2026. FL ch. 507. NY still uses order for service.
11Community tactics
- Look up the USDOT number — Verified. FMCSA HHG search + SAFER.
- Written binding estimate after walkthrough before deposit — Verified. 375.401 / 375.403 / 375.405; FAQ.
- SAFER fields: Entity Type Carrier, USDOT Active, Operating Authority Authorized for HHG — Verified.
- Forgotten-garage requote — Verified as mechanics. Post-load amendment is barred.
- Spot brokers; check BOL header for the actual carrier — Verified. FAQ + 375.409.
- Don’t pay deposits by Zelle — Partly. No FMCSA Zelle ban; rule is form-of-payment on the estimate.
- Hostage: tender 110%/100% then complain — Verified (FAQ + 375.407 + 14915). Police cooperation unverified.
- Video walkthrough to estimate cubes — Partly. Virtual survey is a lawful physical survey (375.103).
12Fact-check notes
- FMCSA FAQ (https://www.fmcsa.dot.gov/protect-your-move/faq) — works, updated October 8, 2026. Supports 110% non-binding / 100% binding at delivery, 30-day additional-charge billing, complaint.fmcsa.dot.gov and 1-888-368-7238.
- FMCSA consumer-rights page — works. Last30days-cited handbook PDF
.../2023-10/FMCSA_R&R_Handbook_Web_v1.pdf— broken (404); do not cite; use the consumer-rights page and FAQ. - 49 CFR 375.407 via Cornell — works (eCFR returned a CAPTCHA in research).
- FMCSA subpart D how-to — works (updated February 2, 2015).
- DOT OIG Abda (https://www.oig.dot.gov/library-item/47064) — works, October 6, 2025; restitution $1,908,486.
- NBC, ProPublica, Pennsylvania Insurance, CFPB car/yo-yo pages — not cited in r2 §4.
13Tools to implement
Show the tool specifications
- USDOT/MC verifier. Inputs: name or USDOT or MC. Logic: pull HHG search + SAFER; flag broker-only, zero trucks, inactive, missing HHG. Data: https://ai.fmcsa.dot.gov/hhg/search.asp ; https://safer.fmcsa.dot.gov/ ; QCMobile REST https://mobile.fmcsa.dot.gov/qc/services (Login.gov WebKey).
- 110% tender calculator. Inputs: estimate type, estimate dollars, claimed extras, impracticable-ops flag. Logic: due_now = binding ? estimate : min(actual, 1.10 × estimate); extras_now = min(impracticable, 0.15 × due_now). Data: FMCSA FAQ (https://www.fmcsa.dot.gov/protect-your-move/faq); 49 CFR 375.407 (https://www.law.cornell.edu/cfr/text/49/375.407).
- Valuation + claims clock. Inputs: weight, declared value, FVP waiver, delivery date, denial date. Logic: Released = lb × $0.60/article; FVP floor = max(6 × lb, 6000); claim due = delivery + 9 months; suit due = denial + 2 years. Data: STB RR 999 Amd. 5 (https://www.stb.gov/wp-content/uploads/files/docs/householdGoodsMoving/41845.pdf); 49 U.S.C. 14706.
14Sources
- 01
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- 03
- 04
- 05
- 06
- 07
- 08
Demand evidence r2 F4×P5×S5 = 100; r1 $50k-loss thread plus r2 viral scam videos; FMCSA FAQ “110% of non-binding / 100% of binding” (updated October 8, 2026)