Fraud Investigation7 min

FMCSA Has a Safety System. It Has Nothing for Fraud.

The agency responsible for protecting consumers from moving fraud has never built the tools to do it.

Two Systems, One Blind Spot

FMCSA operates the Safety Measurement System (SMS) to score carriers on safety violations, crash history, and inspection results. It works. Dangerous trucking companies get flagged and eventually shut down. But for household goods fraud, including overcharging, hostage loads, bait-and-switch pricing, and stolen goods, there is no equivalent system. No fraud score. No pattern detection. No automated enforcement triggers.

The SMS proves that FMCSA can build effective monitoring infrastructure. The absence of anything comparable for consumer fraud is a policy choice, not a technical limitation.

Where Complaints Go to Die

Consumer complaints about moving fraud go to FMCSA's complaint intake division. According to practitioners who have worked with the agency, FMCSA's complaint intake process logs complaints but rarely initiates enforcement. Lewie Pugh, Executive Vice President of OFMCSA's complaint intake process (Owner-Operator Independent Drivers Association), described it in February 2025 Senate Transportation Committee testimony as the place "where complaints go to die." The complaints create a paper trail but generate no consequences for the carrier.

This matters because consumers are told to file FMCSA complaints as their primary remedy. The agency's own website directs victims of moving fraud to the complaint hotline. But filing a complaint with an office that does not act on complaints is not a remedy. It is a placebo.

The OIG Has Never Looked

FMCSA's Office of Inspector General has never audited the agency's household goods enforcement practices. FOIA requests have confirmed no systematic review exists. The agency has been pressured on safety enforcement by Congress and advocacy groups, but household goods fraud has received virtually no oversight attention.

This is remarkable given the scale of the problem. FMCSA's own complaint data shows thousands of household goods complaints per year. Yet no one inside the agency has been asked to evaluate whether the enforcement apparatus is working.

Section 14704: The Consumer Remedy Nobody Implements

Section 14704 of the amended Motor Carrier Act provides an adjudicatory remedy for consumers damaged by regulatory violations and moving fraud at DOT's Office of Hearings and the federal Surface Transportation Board for many household goods disputes. The Secretary of Transportation (DOT) is responsible for writing rules of practice implementing this procedure for Office of Hearings cases. In 31 years since Congress created this remedy, DOT has failed to do so. The statute provides real authority: DOT's Office of Hearings, or the Surface Transportation Board (depending on the nature of the claim), can find regulatory violations and order payment of refunds and other damages to consumers. An Office of Hearings finding, in turn, creates a record that would support an FMCSA enforcement remedy or HHG license suspension for the carrier or broker. Attorney fees will be assessed if federal court intervention is required for collection of the consumer remedy. But without implementing regulations, filing procedures, and other consumer guidance by FMCSA, the law functions as a theoretical protection that requires extraordinary legal knowledge to invoke.

Operation Protect Your Move: Enforcement Theater

FMCSA's highest-profile enforcement effort, Operation Protect Your Move (2023-2024), targeted 142 movers in 17 states over a period of weeks. Of those, 93 were investigated and 44 were inspected. The results: 180 consumer complaints were substantiated, enforcement action was limited to letters of probable violation, notice of claim, and notice of violation. Two license suspensions resulted, both for safety violations, not for consumer fraud. No movers involved in economic fraud or scam patterns were identified in the report, and no referrals to the Department of Justice were mentioned. The 2019 Riojas decision (FMCSA-2012-0174) stripped FMCSA of administrative civil penalty authority for household goods violations, leaving the agency with negligible financial deterrent against fraud. FMCSA can still refer cases to OIG for DOJ court-imposed civil penalties, but this path is rarely pursued.

Why Independent Verification Fills the Gap

When the regulator doesn't enforce, consumers need alternative sources of truth. Trunk exists because FMCSA doesn't do this job. We verify licensing, cross-reference complaints across eight sources, flag chameleon carriers, and document fraud patterns that the agency's systems are not designed to detect.

Trunk tracks over 4,200 movers. For each one, we assemble data from FMCSA records, Google reviews, Yelp, BBB complaints, Reddit threads, Facebook community groups, MovingScam.com, and expert interviews. We look for the patterns that FMCSA's complaint system does not surface: the same owner appearing under multiple company names, rental trucks replacing owned fleets, review manipulation across platforms, and complaint volumes that diverge dramatically from official ratings.

This is not a replacement for regulation. Consumers deserve both an effective federal watchdog and independent verification platforms. But until FMCSA builds fraud detection infrastructure comparable to what it has for safety, platforms that assemble publicly available data will remain the primary line of defense.

The Agency's Own Admission

FMCSA's internal enforcement policy memo (MC-ECE-2020-0001, dated February 20, 2020) explicitly acknowledges the impact of the Riojas decision on the agency's ability to enforce household goods regulations. The memo states that FMCSA 'lacks express statutory authority to assess civil penalties using its administrative proceedings' for Riojas-affected violations. The memo lists alternative enforcement tools including Notices of Violation, suspension of operating authority, and out-of-service orders, but notes that many of the affected violations have been 'rarely enforced in the past 6 years.' The policy cancels the agency's 2015 procedure for compensating hostage load victims through settlement agreements. It supersedes or modifies at least eight previous enforcement policies dating back to 2012, including 'Procedures for Investigating Potential Reincarnated/Chameleon and Affiliated Motor Carriers' (2012) and 'Enforcement of Violations for Holding Household Goods Hostage' (2014). The document is a roadmap of an enforcement apparatus that was dismantled piece by piece.

The Numbers: Enforcement in Free Fall

FMCSA's own data tells the story. National closed carrier enforcement cases dropped from 3,794 in FY 2024 to 1,312 in FY 2025, a 65% decline in a single year. Through mid-May of FY 2026 (7.5 months into the fiscal year), only 406 cases had closed. Projected at the same rate for the remainder of the fiscal year, FY 2026 will close approximately 650 carrier enforcement cases, representing 50% of FY 2025 and 17% of FY 2024 levels. Broker enforcement is even starker: 10 closed cases nationally in FY 2024, zero in FY 2025, zero in FY 2026. Not reduced. Zero. Across all regions, FY 2025 enforcement ran at 27% to 39% of FY 2024 levels. In 2025, FMCSA conducted 7,020 total carrier investigations, of which only 167 involved household goods carriers, despite 3,226 NCCDB complaints filed that year. Those 167 HHG investigations found 1,057 violations, an average of 6.3 violations per carrier investigated. When FMCSA does investigate an HHG carrier, it finds violations. It just rarely investigates. When HHG carriers are investigated, they average 5.5 violations per inspection, compared to 5.0 for all carriers. Nearly all HHG violations (921 of 925) are classified as non-acute and non-critical, meaning they are consumer protection violations, not safety hazards. FMCSA's investigation apparatus is designed to find safety problems. When it looks at HHG carriers, it finds consumer fraud instead.

Update (July 30, 2026): U.S. Senators Maria Cantwell and Edward Markey sent a letter to FMCSA Administrator Derek Barrs citing these same enforcement decline figures and demanding answers by August 12. A ProPublica/WBUR investigation found that FMCSA's crash data has similar attribution problems: 42 fatal crashes involving one bus company were missing from that company's FMCSA records because they were filed under the names of contracting agencies. The data integrity problem extends beyond household goods.

Convicted Fraudsters Get New Authority

FMCSA's registration system contains no mechanism to flag applicants who are convicted moving fraud defendants. In a documented case, Farah Al-Ibrahim was convicted in federal court (D.NJ, Case 2:19-cr-00140) for conspiracy to commit wire fraud through a network of moving companies that systematically overcharged consumers. She was sentenced to probation and $75,193 in restitution, of which she paid approximately $4,900 (6.5%) before her supervision expired. In January 2023, while still on criminal probation, she incorporated a new company (Booking Agency USA Ltd) in New Jersey and obtained FMCSA household goods broker authority. The agency that is supposed to vet carriers and brokers for 'competence, fitness, and willingness' to comply with regulations issued a new license to a convicted moving fraud conspirator serving a criminal sentence. Criminal enforcement actions are not reported on FMCSA's consumer-facing website and are invisible to consumers researching movers.

Congress Acts on Trucking Fraud, but Not Moving Fraud

Congress is not unaware that fraud exists in the trucking industry. In July 2026, the Senate introduced a bill to make staged truck crashes a federal crime, carrying up to 20 years in prison, or a minimum 20-year sentence if the staged crash results in serious injury or death. The same month, 12 people were arrested in a $2 million cargo theft scheme. These enforcement actions demonstrate that Congress can act on transportation fraud when it chooses to.

But household goods moving fraud, which affects hundreds of thousands of consumers annually, has no equivalent legislative momentum. H.R. 880, the Consumer Protection in Commerce Act, would strengthen FMCSA's HHG enforcement tools, but it has not advanced. The contrast is telling: staged crashes endanger truckers and insurers, powerful constituencies with lobbyists. Moving fraud victimizes individual consumers with no organized representation.

NCCDB: A Database Consumers Cannot Use

FMCSA's National Consumer Complaint Database (NCCDB) allows consumers to submit complaints but not to research movers. Complaint data is used 'for analytical and statistical purposes' by the agency and may 'trigger investigation' of the mover, but FMCSA does not inform consumers or the public if complaints produce results. The agency 'tracks enforcement actions through a separate system and does not identify if a complaint led to an enforcement action' (GAO-23-105972, September 2023). Consumers can file complaints on the NCCDB webpage but cannot search for complaint histories against specific movers. A search for individual movers elsewhere on FMCSA's website reveals only opaque NCCDB data with no transaction details. By contrast, DOT's Aviation Consumer Protection Division has made consumer complaint data available and transparent for over 25 years. BBB consumer complaints are available with transparent details. As OFMCSA's complaint intake process's vice president Lewie Pugh told the Senate Transportation Committee in February 2025: 'it seems like the consumer complaints database is where all complaints go to die at FMCSA. There's not a safety effect to this. So that's why they don't have to do anything with this.'

Evidence

FMCSA internal enforcement policy (February 2020): the agency's own documentation of how the Riojas decision dismantled its household goods enforcement tools.

FMCSA internal enforcement policy (February 2020): the agency's own documentation of how the Riojas decision dismantled its household goods enforcement tools.

FMCSA data: 7,020 carrier investigations in 2025, only 167 were HHG carriers. Zero broker enforcement cases in FY 2025 and FY 2026. Source: FMCSA Analysis and Information Online.

FMCSA data: 7,020 carrier investigations in 2025, only 167 were HHG carriers. Zero broker enforcement cases in FY 2025 and FY 2026. Source: FMCSA Analysis and Information Online.

Closed enforcement cases collapsed from 3,794 (FY 2024) to 1,312 (FY 2025). Broker enforcement: zero in FY 2025 and FY 2026. Source: FMCSA Enforcement Programs.

Closed enforcement cases collapsed from 3,794 (FY 2024) to 1,312 (FY 2025). Broker enforcement: zero in FY 2025 and FY 2026. Source: FMCSA Enforcement Programs.

Letter to Representatives Norton and Ezell supporting H.R. 880, the Household Goods Shipping Consumer Protection Act. The bill would restore FMCSA civil penalty authority stripped by the 2019 Riojas decision.

Letter to Representatives Norton and Ezell supporting H.R. 880, the Household Goods Shipping Consumer Protection Act. The bill would restore FMCSA civil penalty authority stripped by the 2019 Riojas decision.

Sources: FMCSA SAFER database. FMCSA complaint data (FMCSA's complaint intake process). Surface Transportation Board, Section 14704 of the Interstate Commerce Act. FOIA responses. Trunk mover database (4,200+ carriers tracked). Expert interviews with legal professionals specializing in moving fraud. Facebook community groups including "Moving? Tips on moving & avoiding Moving Scams.". AGOYU Moving Guides, "Moving Scams: Confronting Ongoing Consumer Hardships Amidst Token Federal Crackdowns" (2024).

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