3,000 Pages of Instructions and No One to Follow Them

In June 2026, a retired transportation attorney submitted detailed evidence to FMCSA's Commercial Enforcement and Investigations unit documenting that JCS Moving and Storage was a chameleon reincarnation of Handle With Care Moving, a carrier whose authority had been revoked three times. He provided the incorporator match, the personnel overlap, the broker connection, the complaint trajectory. He submitted the same evidence to FMCSA's Southern regional administrator and the Georgia state administrator.

The CEI unit responded with an automated message directing him to file a consumer complaint. The regional and state administrators did not respond or acknowledge.

JCS continued to operate. It accumulated 47 complaints. A driver extorted a consumer fleeing domestic violence for $1,000 cash on the truck. Consumer belongings ended up in a storage unit rented under the driver's personal name.

The evidence was clear. The tools to act existed. The action did not happen. This article explains why.

Every FMCSA field investigator operates under the Electronic Field Operations Training Manual (eFOTM), currently at Version 10.1. The manual and its appendices total approximately 2,000 pages. They cover every aspect of how an investigator conducts compliance reviews, safety audits, new entrant audits, and enforcement actions.

The eFOTM is not a summary or a checklist. It is a comprehensive procedural manual that specifies how to open a case, what documentation to collect, how to interview witnesses, how to calculate civil penalties, how to prepare enforcement recommendations, and how to navigate the administrative process from investigation through adjudication.

The appendices (Part 2) contain the detailed procedures, checklists, worksheets, and forms that investigators must complete. Each type of investigation has its own procedures, its own required documentation, and its own review chain.

FMCSA released the eFOTM through a Freedom of Information Act request. It is available on FMCSA's website.

In 2009, FMCSA published a Federal Register notice (74 FR 24891, May 26, 2009) titled 'Purpose, Use and Effect of Field Operations Training Manual.' The notice was prompted by carriers and brokers arguing in enforcement proceedings that the FOTM had the force of law and that investigators who deviated from it had violated their rights.

FMCSA clarified that the FOTM is internal guidance. It instructs investigators on procedures but does not create enforceable rights for carriers or brokers. An investigator who follows the manual to the letter has done their job. An investigator who deviates from it has not necessarily committed a legal error.

This clarification cuts both ways. The manual protects FMCSA from challenges based on procedural deviations. But it also means the manual's procedures are aspirational, not mandatory. An agency that cannot staff its procedures can simply not follow them without legal consequence.

In 2020, the situation became worse. The Riojas ALJ decision stripped FMCSA of civil penalty authority for commercial regulation violations. This includes violations of 49 CFR 371.3 (broker transparency), 49 CFR 375 (household goods consumer protection regulations), and other commercial rules that protect consumers.

FMCSA issued an internal policy memo adjusting enforcement procedures in response. Investigators were instructed on how to handle cases where they could document violations but could not assess penalties.

The practical effect: an investigator who navigates the eFOTM procedures, completes the required documentation, conducts the interviews, prepares the enforcement recommendation, and submits it through the review chain may arrive at the end of the process and discover that the violation they documented cannot be penalized.

Safety violations (crashes, inspections, hours of service) retained penalty authority. Commercial violations (the ones that govern consumer protection in household goods) did not. The enforcement system retained its full procedural complexity while losing its ability to produce consequences for the violations consumers actually experience.

FMCSA has not publicly disclosed how many investigators are assigned specifically to household goods enforcement. What is known:

The agency reports 7,632 carriers with HHG authority and approximately 900 HHG brokers. The NCCDB received over 4,400 household goods complaints in 2025. FMCSA's enforcement data (EMIS, downloaded by Trunk for all 50 states) shows 13 total broker enforcement cases closed nationally in seven years (FY 2020 through 2026), producing $116,634 in settlements. Carrier enforcement dropped 75% or more in every major state between FY 2024 and FY 2026.

The eFOTM procedures for a single compliance review require weeks of investigator time. Document collection, on-site inspection, witness interviews, violation documentation, penalty calculation, supervisory review, legal review, and case preparation. Each step has its own eFOTM procedures.

With 4,400 annual complaints, 8,500+ regulated entities, a 2,000-page procedural manual, and whatever investigative staff the agency has assigned to HHG, the arithmetic produces the outcome we observe: 13 broker cases in seven years.

The system is not failing to work. It is working exactly as its resource allocation dictates.

When a consumer files an FMCSA complaint, the complaint enters a system that was designed for a different scale. The eFOTM procedures assume investigators have time to conduct thorough reviews. The staffing levels do not support that assumption for household goods.

The complaint becomes a data point in the NCCDB. It appears on the carrier's public record. It may contribute to a pattern that eventually triggers a compliance review. But the path from complaint to enforcement action passes through 3,000 pages of procedures, a staffing bottleneck the agency has not disclosed, and a penalty framework that may not allow consequences even if the investigation is completed.

This does not mean filing complaints is pointless. Complaint data is what makes the pattern visible. It is what journalists use to identify the worst operators. It is what state attorneys general cite when they take action that FMCSA does not. It is what Trunk uses to flag companies and document fraud networks.

But consumers should understand that filing with FMCSA is documentation, not enforcement. The enforcement system exists on paper. The capacity to operate it at scale does not.

For immediate help: file a chargeback if you paid by credit card. File a police report if your belongings are being held. Contact your state attorney general. Report to Trunk at trunk.lorea.ai/report-mover. These channels produce faster results than the federal complaint-to-enforcement pipeline.