FMCSA's Own Rules Say They Should Have Caught This

FMCSA has rules. It publishes them on its website. It describes a vetting process for new applicants. It requires carriers to disclose relationships with other regulated entities. It collects thousands of consumer complaints per year. It has the statutory authority to suspend or revoke operating authority for violations.

The rules exist. The data exists. The authority exists. The enforcement does not.

This article compares what FMCSA says it does with what it actually does, using specific cases where the agency's own published standards were not met.

FMCSA's published FAQ describes its application vetting process. The agency states it evaluates:

- 'The nature and extent of existing or past violations' - 'Whether existing or past regulatory or statutory violations are the result of a willful failure to comply' - 'The existence and nature of pending and closed enforcement actions' - 'Whether adequate safety management controls exist'

Applicants must disclose 'any relationships involving common stock, common ownership, common management, common control or familial relationships with any FMCSA-regulated entities.'

This sounds rigorous. It describes an agency that checks backgrounds, cross-references records, and verifies applicant claims before granting authority to transport consumers' household goods.

But the vetting criteria reference only FMCSA-regulated violations. They do not cross-reference applicants against other federal enforcement databases. Eagle Moving Group Inc. (DOT 3545015), the broker in one of the documented cases in this report, filed its MCSA-1 application listing Jeffrey Griest as President. But the contact email on the application is FRANKD410@GMAIL.COM. The application says Jeffrey Griest is the sole officer and contact person. Who is Frank? FMCSA's vetting process does not investigate discrepancies between listed officers and contact information.

Michel Jean Geraud (aka Mike Jeraux) received a permanent injunction from the Commodity Futures Trading Commission in 2006 for commodities fraud (CFTC v. G7 Advisory Services LLC, S.D. Florida, Case 05-80313). He subsequently obtained FMCSA HHG broker authority for America First Moving Services (DOT 3709259, Deerfield Beach FL). A consumer who hired his company for a one-mile local move was charged a $2,000 binding estimate fee on a $3,978 total estimate. The Florida Attorney General served him with an investigative subpoena in October 2025. He did not comply.

FMCSA's vetting process did not flag a prior federal fraud injunction because it does not look beyond its own database.

In 2012, Congress required FMCSA to develop a proficiency examination for HHG carrier applicants to demonstrate knowledge of and compliance with regulations. A private attorney, Michael Garcia, published a 36-page study guide and compliance test for the exam in 2015 (ISBN 978-0692412183), anticipating its implementation. As of 2026, FMCSA has still not administered the test. It remains on the agency's to-do list, 14 years after Congress required it. The study guide for a test that was never given is available on Amazon for $89.99.

Howards Vanlines (DOT 4391903) applied for household goods carrier authority. Its first application was dismissed by FMCSA on May 19, 2025. Four months later, a second application was granted on September 26, 2025.

The principals were Karim Hassan and Ahmad Riyad Alomari. Their undisclosed principals appear to include Joseph Hannouch and Farah Al-Ibrahim, a convicted moving fraud conspirator. Al-Ibrahim was convicted of conspiracy to commit wire fraud (D.NJ Case 2:19-cr-00140) and sentenced to probation and $75,193 in restitution. While on criminal probation, she incorporated a new company (Booking Agency USA Ltd) and obtained new FMCSA broker authority.

FMCSA's vetting criteria require evaluation of 'existing or past violations' and 'willful failure to comply.' The agency dismissed the first application but approved the second, from the same principals, four months later.

After approval, Howards claimed '60+ years of moving expertise' while operating a single box truck. It stole the identity of a legitimate carrier, Howard's Van Lines of Dayton, Ohio (DOT 1245219). In eight months, it accumulated 89 NCCDB complaints, including hostage loads, bait-and-switch pricing ($3,968 to $11,881 in one case), and unauthorized brokering.

On May 28, 2026, a retired attorney sent a formal enforcement request to Administrator Barrs and eight named officials citing nine statutory violations. FMCSA did not acknowledge receipt.

The OP-1 application requires carriers to answer 'whether you currently have, or had within the last 3 years of the date of filing the application, any relationships involving common stock, common ownership, common management, common control or familial relationships with any FMCSA-regulated entities.'

This is the chameleon carrier question. It asks applicants to disclose connections to other carriers or brokers, specifically to prevent operators from dissolving a company with a bad record and starting fresh under a new name.

Handle With Care Moving and Transportation (DOT 3190967, Tucker, GA) had its FMCSA authority revoked three times: 2021, 2022, and March 30, 2026. Five days before the third revocation, JCS Moving and Storage was registered by the same incorporator, with the same employees, dispatched by the same Florida broker (Menards Moving and Storage).

A retired attorney notified FMCSA of the reincarnation twice (June 19 and July 1, 2026), providing the complete roadmap: same person, same employees, same broker, same address cluster. FMCSA's Commercial Enforcement and Investigations unit responded with an automated message directing him to file a consumer complaint on NCCDB, which has no reincarnation reporting mechanism.

JCS continued to operate. It accumulated 20+ complaints in its first four months.

The OP-1 application asks about affiliations. The applicant answered (or failed to answer). FMCSA did not verify. The bipartisan SAFE Act, introduced in July 2026, aims to automate this verification. But the disclosure requirement already exists. The agency already has the data to cross-reference. It does not do so.

FMCSA's Protect Your Move website tells consumers that their NCCDB complaints 'are used for analytical and statistical purposes' and 'may' help the agency decide which movers to investigate.

The NCCDB collected 9,128 moving company complaints in 2021. As of 2025, it collects roughly 4,481 per year. The data exists. It is organized by category (Estimates/Final Charges, Hostage Goods, Deceptive Business Practices, etc.), by carrier, and by year. Between 2006 and 2014, total FMCSA fines against all carriers nationwide ranged from $17 million to $36 million per year. The largest single fine against a moving company was $281,100 in 2010. Average individual fines ranged from $30,000 to $75,000. For companies generating millions in coerced overpayments, these penalties are a cost of doing business.

In FY 2025, FMCSA closed zero broker enforcement cases. National closed carrier enforcement cases dropped 65% from FY 2024. Of 7,020 carrier investigations in 2025, only 167 involved household goods carriers, despite over 3,200 consumer complaints.

Safe Ship Moving Services has 404 NCCDB complaints, the most of any company in the database. It continues to operate. Menards Moving and Storage has 290 complaints, 156 in the first half of 2026 alone. It continues to operate. Howards Vanlines has 166 complaints from one registered truck. It continued to operate for months after a formal enforcement request was filed.

The complaint data exists. The analytical purpose it serves is unclear. The enforcement actions it triggers are, in practice, zero.

A 2023 GAO report found that FMCSA 'tracks enforcement actions through a separate system and does not identify if a complaint led to an enforcement action.' The agency collects complaints and tracks enforcement, but does not connect the two. Complaints go in one database. Enforcement decisions are made in another. No system links a consumer's complaint to any outcome.

OOIDA's Lewie Pugh described the NCCDB in February 2025 Senate testimony as 'where complaints go to die.'

Across every case Trunk has documented, the pattern is the same. FMCSA has the rules, the data, and the authority. It publishes criteria that sound rigorous. It collects complaints that document violations. It has statutory tools, including civil penalties, license suspension, and revocation, that it could apply.

It does none of these things for household goods consumer protection. The safety enforcement apparatus works. The consumer protection apparatus does not exist in practice.

The gap is not legal authority. It is not data. It is not staffing alone, though staffing is inadequate. The gap is institutional priority. Household goods consumer protection is not something FMCSA does. Its published rules create the appearance of protection. Its actual operations deliver none.

GAO said this in 2001. GAO said it again in 2009. GAO documented it again in 2023. In June 2023, Newsweek found that at least 18 companies with revoked licenses continued to advertise interstate moves. FMCSA's response: it would 'look at each case individually.' License revocation, the agency's primary enforcement tool, does not stop companies from operating. The pattern has not changed in 25 years.