FMCSA Says Protecting Your Move Is Your Responsibility. Following Their Instructions Would Take 40 Hours.

FMCSA's Protect Your Move website opens with a clear statement of who is responsible when a move goes wrong: 'The primary responsibility for protecting your move lies with you in selecting a reputable household goods mover or household goods broker.'

A transportation attorney who has represented moving fraud victims for years offered a blunt response: 'The simple truth is that consumers do not and will not do the research in advance of their move.'

Both statements are true. FMCSA places the responsibility on consumers. Consumers do not fulfill it. The question nobody has asked is: how much time would it actually take to follow every instruction FMCSA provides?

FMCSA's Protect Your Move website, linked publications, and consumer brochures collectively recommend the following steps before hiring a mover. We extracted each instruction and estimated the minimum time a diligent consumer would need:

1. Check the FMCSA registered mover database for authority, insurance, complaint history, and safety information. (30 min per company, 3 companies = 1.5 hrs)

2. Get written estimates from several movers, based on in-person inspections, and compare them. (Scheduling and conducting 3 in-home surveys = 6 hrs)

3. Check the BBB and local consumer protection agencies for reports on the moving company and broker. (30 min per company, 3 companies = 1.5 hrs)

4. Read the 'Your Rights and Responsibilities When You Move' handbook and the 'Ready to Move?' brochure. (1 hr)

5. Learn the difference between a moving broker and a moving company. (30 min)

6. Understand the difference between a binding estimate and a non-binding estimate. (30 min)

7. Determine that any estimate and bill of lading are consistent with the carrier's tariff. (Request tariff, read 40-75 pages of legal/regulatory text, compare line items = 4 hrs)

8. Ask a broker for a list of the moving companies the broker uses. (15 min)

9. Confirm the broker's moving companies are registered with FMCSA. (If the broker provides a list of 100+ carriers, checking each one = 8-15 hrs)

10. Ask if the broker has a written agreement with the movers it uses. (15 min)

11. Ask to see the broker's marketing materials, ads, and website. (30 min)

12. Learn to spot the red flags of moving fraud: watch FMCSA's educational video, study the list of red flags (no on-site inspection, large deposit, blank documents, website quality, insurance representations, condition of offices and warehouse, use of rental trucks, revised estimates). (2 hrs)

13. Read and understand the estimate, Bill of Lading, and inventory list. (1 hr)

14. Read and understand mover liability and insurance options: Full Value Protection, 60 cents per pound, purchased insurance. (1 hr)

15. Ask about and understand the arbitration and dispute settlement procedures of the carrier and broker. (30 min)

16. Ask the carrier and broker about contact information during the move. (15 min)

17. Ask about and understand terms of payment, deposit, pickup, delivery, and other conditions. (30 min)

Minimum estimated time to complete all 17 steps for a single move with three comparison quotes:

Research and database checks: 6 hours In-home surveys: 6 hours Reading regulatory documents: 6 hours Tariff review and comparison: 4 hours Carrier list verification: 8-15 hours Red flag education: 2 hours Contract and document review: 3 hours Questions and follow-up: 2 hours

Total: 37 to 44 hours.

At $71 per hour, the rate FMCSA itself uses to estimate the cost of regulatory compliance burden on businesses (87 FR 24442), the consumer's 'responsibility' costs $2,627 to $3,124 in time.

This is more than most consumers pay for the move itself.

When FMCSA proposes a rule that requires businesses to gather or report information, federal law (the Paperwork Reduction Act of 1995 and the Regulatory Flexibility Act of 1980) requires the agency to estimate the time and cost burden on affected businesses. The agency must justify that the burden is reasonable and give special attention to any disproportionate impact on small businesses.

In the 2022 final rule implementing the HHG Working Group recommendations (87 FR 24431), FMCSA estimated the per-carrier compliance burden at $71 per hour, with a net savings of $187 per year per carrier.

In June 2025, FMCSA published its latest PRA renewal for the HHG consumer protection information collection (90 FR 27067, Docket FMCSA-2025-0003, OMB Control Number 2126-0025). The filing calculates the total annual burden on 7,861 household goods carriers at 3,722,704 hours, approximately 474 hours per carrier per year. The agency calculated, to the hour, how much time carriers spend filling out Bills of Lading, conducting surveys, preparing inventories, maintaining complaint records, and providing consumer pamphlets. No comments were received on the prior 60-day notice.

No equivalent analysis has ever been performed for the 17 steps FMCSA recommends to consumers. The agency quantifies and minimizes the cost of compliance for industry. It does not quantify or acknowledge the cost of compliance for consumers.

The PRA does not technically require this calculation for voluntary consumer guidance (as opposed to mandatory business reporting). But the asymmetry is concrete: FMCSA knows that 7,861 carriers spend 3,722,704 hours per year on paperwork. It has no idea how many hours 8 million annual interstate movers would spend following its 17-step guidance, because it has never asked the question.

Most of the 17 steps take 15 to 60 minutes. Step 9 takes days.

FMCSA recommends that consumers 'confirm the broker's moving companies are registered with FMCSA.' Safe Ship Moving Services publishes a list of 1,080 carriers. Verifying each one, checking authority status, insurance, complaint history, and safety data, would take approximately 5 minutes per carrier. For 1,080 carriers: 90 hours.

No consumer will spend 90 hours verifying a broker's carrier list. But Trunk did. We found that 100 of Safe Ship's 1,080 carriers have revoked or inactive FMCSA authority. Their combined complaint count is 2,954.

The data was there. FMCSA's instructions were correct. No individual consumer would ever find it. This is why data platforms that automate the verification process exist. The 40-hour consumer responsibility can be reduced to a 5-minute search on a platform that has already done the work.

FMCSA is not wrong that consumers should research their movers. The agency is wrong that 'the primary responsibility' lies with the consumer.

The primary responsibility lies with the agency that registers movers, maintains the complaint database, and has the statutory authority to revoke the licenses of companies that defraud consumers. When that agency registers a company in 20 minutes for $300, does not verify the applicant's criminal history, does not cross-reference the applicant against prior revocations, and then tells consumers to spend 40 hours researching the company it just licensed, the responsibility has been transferred, not shared.

Consumers should research their movers. They will not spend 40 hours doing it. Platforms that automate the research (Trunk, USMPO, MovingScam) reduce the burden from 40 hours to minutes. But the fact that these platforms are necessary, that private organizations must build the consumer protection infrastructure the federal agency was designed to provide, is itself evidence of the enforcement gap.

FMCSA's 17-step consumer responsibility list is not consumer protection. It is a liability transfer. When the move goes wrong, the agency can point to the list and say: we told you what to do. The consumer did not do it. Not our problem.