Fraud Investigation8 min

You Already Have Full Value Protection. Here Is How Brokers Take It Away.

Federal law gives consumers Full Value Protection by default. To drop to $0.60 per pound, YOU must sign a waiver. Trunk reviewed court-filed estimates from five brokers and found three distinct methods used to strip consumers of coverage they never knew they had.

|Trunk Research|With John H. Vetne
Comment

Most consumers believe they need to buy better moving coverage. They do not. They already have it.

Under federal law (49 CFR 375.202), Full Value Protection is the default liability level for every interstate household goods move. The carrier is liable for the full replacement value of anything it loses or damages. To drop to the lower level, Released Value at $0.60 per pound per article, the consumer must sign a written waiver opting out (49 CFR 375.203).

This is not optional for the carrier. FMCSA's own website states: 'Unless you choose the Released Value option, your mover will automatically move your belongings under this level of liability.' The Part 375 Appendix A handbook requires that the initial cost estimate include FVP-level protection.

The waiver must be informed. In AGCS Marine Insurance Co. v. Chillicothe Metal Co., 651 F. Supp. 3d 954, 961 (C.D. Ill. 2023), the court held that an effective liability waiver requires 'both reasonable notice of the liability limitation and the opportunity to obtain information necessary to making a deliberate and well-informed choice.' A signature on a waiver line is not enough if the consumer can demonstrate they lacked the information needed.

Trunk reviewed court-filed estimates and consumer-submitted documents from five brokers and carriers. Three distinct patterns emerged. One is legitimate. Two are not.

Important: This Is Not Insurance

Before examining the patterns, a critical distinction. Neither Full Value Protection nor Released Value is insurance. Both are expressions of liability assumed by the carrier. The carrier promises to pay for loss or damage up to the declared value.

If the carrier is insolvent, disappears, or refuses to pay, the consumer's recourse is limited. The FMCSA-mandated BMC-34 cargo bond provides only $5,000 in coverage, and that amount may be diluted across multiple claimants. A consumer whose carrier vanishes with $50,000 in belongings has a $5,000 bond shared with every other victim.

This makes the FVP waiver even more consequential than it appears. The consumer is not choosing between two insurance policies. They are choosing between a carrier's promise to pay full replacement value and a carrier's promise to pay $0.60 per pound. If the carrier does not honor either promise, the fallback is $5,000 total.

Pattern A: The $0.00 Valuation Charge (Most Common)

In this pattern, the estimate shows the FVP valuation charge as $0.00 at every deductible level. The total estimate is identical whether the consumer selects FVP with a $0 deductible or FVP with a $1,500 deductible. The cost is the same. The consumer is then asked to initial or sign a waiver line choosing Released Value.

This is the most common format used by brokers and carriers identified in consumer fraud complaints.

Documented examples:

Safe Ship Moving Services (2022, court-filed estimate, Palm Beach County Case 502022SC015351XXXXSB): FVP Amount of Liability: $56,700. Valuation Charge: $0.00 at every deductible level ($0, $250, $500, $750, $1,000, $1,500). Total Estimate Plus Valuation Charge: $9,708.90 regardless of selection. Rep: Bruce.

Menards Moving and Storage (2026, consumer estimate): FVP Amount of Liability: $34,146. Valuation Charge: $0.00 at every deductible level. Total: $4,895.11 regardless. Rep: Teddy Romano.

PrimeLine Van Lines (2024, consumer estimate, 30 Sherwood Lane Ste 6, Fairfield NJ): FVP Amount of Liability: $30,240. Valuation Charge: $0.00 at every deductible level. Total: $5,518.00 regardless. Rep: Tommy. Tariff Discount: 69.30%.

The legal problem: if FVP costs exactly the same as Released Value, no informed consumer would waive FVP. The waiver signature is meaningless under informed waiver standards because there is no economic reason to choose the lower protection. The broker's intent appears to be to offer released rate only, contrary to 49 CFR 375.201, while creating the appearance of a choice that does not exist.

If your estimate shows $0.00 for the FVP valuation charge, you are looking at a red flag. Ask the broker to explain why Full Value Protection costs nothing. If it truly costs nothing, do not sign the waiver.

Pattern B: Legitimate FVP Pricing (Industry Standard)

In 2003, when FMCSA established the current FVP framework, the Federal Register noted: 'The approximate cost for FVP is $8.50 for each $1,000 of declared value' (68 FR 35064, 35103, June 11, 2003). The industry standard range is 1% to 2% of the declared shipment value, varying by deductible level.

Documented example:

Coastal Moving Services (2025, consumer estimate): FVP Amount of Liability: $17,500. Valuation Charges range from $840 ($0 deductible) down to $315 ($1,500 deductible). Total Estimate Plus Valuation Charge ranges from $3,660.25 to $3,135.25 depending on deductible selected. Rep: Daniel Thompson.

This is what a legitimate FVP presentation looks like. The consumer can see the actual cost of protection at each deductible level. The cost is proportional to the declared value. The consumer can make a real, informed choice between paying $315 to $840 more for full replacement coverage or accepting $0.60 per pound.

Note: Coastal Moving Services has 229 NCCDB complaints and is flagged on Trunk for other reasons. The point is not that Coastal is a good company. The point is that even a company with significant complaint issues can present FVP in compliance with the regulation. The companies using Pattern A and Pattern C choose not to.

Pattern C: Predatory FVP Pricing (The Protection Racket)

In this pattern, the broker prices FVP so high that no consumer would select it. The cost is not 1-2% of declared value. It is 10-20%, turning FVP into a theoretical option that functions as a guaranteed waiver.

Documented example:

Safe Ship Moving Services (2025, court-filed estimate, Ke Wang move): FVP Amount of Liability: $34,860. Valuation Charge: $6,972.00 at EVERY deductible level ($0, $250, $500, $750, $1,000, $1,500). The FVP cost does not decrease with higher deductibles. It is $6,972 regardless. That is 20% of the $34,860 cargo value, not the industry standard 1-2%. The FVP charge ($6,972) is nearly equal to the entire shipping cost ($7,484.87). Rep: William Shafer.

At industry standard pricing (1-2%), FVP for a $34,860 shipment should cost approximately $296 to $697 depending on deductible. Safe Ship charged $6,972, ten times the expected cost, at every deductible level.

The consumer's 'choice' is between a $7,485 move with $0.60/lb coverage or a $14,457 move with full value coverage. No consumer facing a $7,485 moving bill is going to double their cost for liability protection. That is the point. The pricing is designed to produce a waiver.

The same company, Safe Ship, used Pattern A (zero-cost FVP) in 2022 and Pattern C (predatory-cost FVP) in 2025. Both achieve the same result: the consumer ends up at $0.60 per pound. The method changed. The outcome did not.

What Consumers Should Do

1. Know that you already have Full Value Protection. You do not need to buy it. You need to not waive it.

2. Read the FVP section of your estimate before signing anything. Look at the Valuation Charge line. If it says $0.00 at every deductible level (Pattern A), ask why. If FVP is free, there is no reason to waive it.

3. If the FVP valuation charge is more than 2% of the declared value of your shipment, ask the broker or carrier to justify the pricing. The federal benchmark is approximately $8.50 per $1,000 of declared value (68 FR 35064). A charge of $6,972 on a $34,860 shipment is not a legitimate offer.

4. Do not sign the Released Value waiver line without understanding what you are giving up. At $0.60 per pound, a $2,000 laptop weighing 4 pounds is covered for $2.40. A $15,000 piano weighing 500 pounds is covered for $300.

5. If you already signed a waiver and believe you were not properly informed, the informed waiver doctrine may apply. Under AGCS Marine v. Chillicothe Metal (C.D. Ill. 2023), a waiver signature is not dispositive if the consumer was not given reasonable notice and the opportunity to make a deliberate choice.

6. File a complaint with FMCSA (nccdb.fmcsa.dot.gov) if your estimate shows Pattern A or Pattern C. These pricing structures may violate 49 CFR 375.201, which requires the estimate to contain FVP-level protection costs.

Data

Three FVP Patterns: How to Read Your Estimate

PatternValuation ChargeWhat It MeansConsumer Action
A: Zero Cost$0.00 at all deductible levelsFVP and Released Value cost the same. Waiver is meaningless.Do not sign waiver. Ask why FVP is free.
B: Industry Standard1-2% of declared value, varies by deductibleLegitimate pricing. Consumer can make informed choice.Compare deductible levels. Consider paying for FVP.
C: Predatory Pricing10-20% of declared value, same at all deductiblesFVP priced to be unaffordable. Designed to force waiver.Do not hire this company. File FMCSA complaint.

Source:

Documented FVP Pricing by Company

CompanyYearPatternDeclared ValueFVP ChargeFVP as % of ValueIndustry Standard Would Be
Safe Ship Moving Services2022A$56,700$0.000%$482 to $1,134
Menards Moving and Storage2026A$34,146$0.000%$290 to $683
PrimeLine Van Lines2024A$30,240$0.000%$257 to $605
Coastal Moving Services2025B$17,500$315 to $8401.8% to 4.8%$149 to $350
Safe Ship Moving Services2025C$34,860$6,97220%$296 to $697

Source:

Companies Mentioned

Contributors: John H. Vetne

Sources: 49 CFR 375.201 (valuation requirements). 49 CFR 375.202 (Full Value Protection as default). 49 CFR 375.203 (Released Value waiver). 68 FR 35064, 35103 (June 11, 2003) (FVP cost benchmark: $8.50 per $1,000 of declared value). AGCS Marine Insurance Co. v. Chillicothe Metal Co., 651 F. Supp. 3d 954, 961 (C.D. Ill. 2023) (informed waiver standard). FMCSA consumer protection guidance (fmcsa.dot.gov/consumer-protection). 49 CFR Part 375 Appendix A (Your Rights and Responsibilities When You Move). Court-filed estimates: Safe Ship (Palm Beach County Case 502022SC015351XXXXSB, 2022), Safe Ship (Ke Wang estimate, 2025). Consumer-submitted estimates: Menards (Griffin, 2026), PrimeLine Van Lines (Martin, 2024), Coastal Moving Services (Escappa, 2025). Analysis and documentary evidence provided by John H. Vetne, retired transportation attorney.

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