Regulatory Analysis6 min

FMCSA's Own Data Is Public by Law. The Agency Makes It Nearly Impossible to Access.

Federal law requires agencies to provide 'timely and equitable access' to public data in machine-readable format. FMCSA blocks automated access with CAPTCHAs, buries complaint narratives behind 11-month FOIA backlogs, and does not offer bulk data downloads. This may violate the Paperwork Reduction Act.

|Trunk Research|With John H. Vetne
Comment

The data that would let consumers identify moving fraud exists. FMCSA has it. Federal law says the agency must make it accessible. The agency does not.

What the Law Requires

The Paperwork Reduction Act (44 USC 3506(d)) requires federal agencies to:

1. 'Ensure that the public has timely and equitable access to the agency's public information.'

2. 'In cases in which the agency provides public information maintained in electronic format, provide timely and equitable access to the underlying data (in whole or in part).'

3. 'Ensure that any public data asset of the agency is machine-readable.'

4. Disseminate public information in 'an efficient, effective, and economical manner.'

5. Encourage 'a diversity of public and private sources for information based on government public information.'

This is not aspirational language. It is a statutory requirement. The Office of Management and Budget (OMB) oversees compliance.

How FMCSA Blocks Access to Its Own Data

FMCSA maintains several databases containing public information about registered moving companies. In practice, accessing this information at scale is obstructed at every level:

The SAFER database (safer.fmcsa.dot.gov) contains registration, insurance, authority status, and complaint counts for every registered carrier and broker. It is publicly accessible one company at a time. There is no bulk download. There is no public API. Automated queries are blocked by reCAPTCHA verification. A researcher attempting to check the authority status of 1,000 carriers (for example, to verify a broker's published carrier list) must manually solve a CAPTCHA for each lookup.

The NCCDB complaint database (nccdb.fmcsa.dot.gov) shows complaint counts by category and year. The actual complaint narratives, the text of what consumers reported, are not publicly accessible. Obtaining them requires a FOIA request. FMCSA's FOIA backlog is 6,256 requests as of Q3 FY 2026, the largest of any DOT component. A consumer waiting for complaint narratives about a company they are considering hiring will wait months. Their move will be long over.

Carrier tariffs are required to be maintained and available to shippers under 49 USC 13702. FMCSA does not collect or publish tariffs. Each carrier maintains its own. Many refuse to provide them when asked. When one consumer requested a tariff from Noble Moving, the company replied: 'Our internal tariff listing is not provided to clients.'

OP-1 applications showing company officers, owners, and disclosed affiliations are filed with FMCSA as part of the public registration process. They are not published online. Obtaining them requires a FOIA request.

What Machine-Readable Means (and What FMCSA Provides)

The PRA requires public data assets to be 'machine-readable.' This means data should be available in formats that software can process: CSV files, JSON APIs, database exports. Not PDFs. Not CAPTCHA-protected web pages that can only be queried one record at a time.

FMCSA provides some data in machine-readable format through its Analysis and Information (A&I) portal. But the most consumer-relevant data, complaint narratives, carrier vetting details, officer information, and tariff rates, is not available in any machine-readable format.

The contrast with other transportation agencies is instructive. The Federal Maritime Commission publishes ocean carrier tariffs online in a searchable format (46 CFR 520). The FAA publishes aircraft registration data as downloadable files. The Surface Transportation Board publishes railroad rate case decisions. FMCSA's household goods data is locked behind CAPTCHAs and FOIA backlogs.

Why This Matters

The PRA's data accessibility requirement exists precisely so that private organizations can build on government data to serve the public. Section 3506(d)(1)(A) specifically calls for 'encouraging a diversity of public and private sources for information based on government public information.'

Trunk exists because FMCSA does not make its data accessible. We built scrapers to extract complaint counts from CAPTCHA-protected pages. We filed FOIA requests for complaint narratives. We cross-referenced SAFER data with BBB, Google, Yelp, Reddit, and Facebook to build the consumer protection platform that FMCSA's data architecture should have enabled but does not.

USMPO built carrier audit systems from the same obstructed data. MovingScam.com has published consumer complaints for 25 years because FMCSA's complaint database does not surface the information consumers need.

Every one of these organizations does work the agency's data systems should make easy. The reCAPTCHA on SAFER does not prevent fraud. It prevents accountability. A consumer trying to verify a carrier is blocked by the same CAPTCHA that blocks a researcher trying to identify patterns across 4,200 movers.

FMCSA's new Motus registration system, launched in May 2026 to replace the legacy system, has introduced additional data integrity problems. In August 2026, Overdrive reported that Motus simultaneously suspended a legitimate carrier (whose active insurance policy is visible on the same screen as the suspension notice) and showed active broker authority for a brokerage with no bond on file. The system that is supposed to be the definitive source of carrier authorization status is producing false positives and false negatives. When the data is not just inaccessible but also wrong, the problem is worse than a PRA violation. It is a system that cannot be trusted.

The Remedy

The Paperwork Reduction Act is enforced by the Office of Management and Budget (OMB). Complaints about agency noncompliance can be directed to OMB's Office of Information and Regulatory Affairs (OIRA).

Specific requests that FMCSA could implement without new legislation:

1. Publish SAFER data as a downloadable bulk file (CSV or JSON), updated weekly. Remove the reCAPTCHA from individual lookups.

2. Publish NCCDB complaint narratives (with consumer PII redacted) as a searchable database, not behind a FOIA wall.

3. Require carriers to file tariffs electronically with FMCSA (or the STB) and publish them online, as the FMC requires for ocean carrier tariffs.

4. Publish OP-1 application data (officer names, disclosed affiliations) as part of the public SAFER record.

None of these require new statutory authority. They require the agency to comply with a law that has been on the books since 1995.

If FMCSA made its data as accessible as the law requires, platforms like Trunk would not need to exist. Consumers could access cross-referenced complaint data directly from the agency that collects it. The fact that independent platforms must build around the agency's data barriers is evidence of the barrier, not justification for it.

Contributors: John H. Vetne

Sources: Paperwork Reduction Act of 1995 (44 USC 3501-3521, specifically 3506(d)). FMCSA SAFER database (safer.fmcsa.dot.gov). FMCSA NCCDB complaint database (nccdb.fmcsa.dot.gov). DOT Chief FOIA Officer Report (March 2026). DOT FY 2026 Quarterly FOIA Reporting. 46 CFR 520 (FMC tariff filing requirements). 49 USC 13702 (HHG tariff requirements).

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