FMCSA New Entrant Audit for Household Goods Movers: What Moving Companies Must Have Ready

Household goods movers -- van lines, local movers, long-distance movers -- face one of the most demanding FMCSA compliance pictures. The standard New Entrant Safety Audit applies the same way it does to any property carrier, and on top of that there is a full consumer protection regime under 49 CFR Part 375 that does not apply to other freight types. Auditors check both. This guide covers what HHG movers specifically need to have ready.

Standard new entrant audit requirements

Every HHG mover with a USDOT number and MC HHG authority is a motor carrier under 49 CFR Part 390. The standard audit applies:

• Driver qualification files under Part 391
• Drug and alcohol testing program under Part 382 (CDL drivers)
• Hours of service records under Part 395
• Vehicle maintenance records under Part 396
• Insurance filings (BMC-91 plus household goods cargo coverage)
• Accident register under 390.15

Household goods consumer protection layer (Part 375)

Part 375 establishes consumer protection requirements unique to interstate HHG transportation. Auditors review:

1. Your Rights and Responsibilities When You Move pamphlet

   Under 375.213, the mover must provide every prospective shipper with the FMCSA-published consumer pamphlet before they sign anything. Distribution must be documented.

2. Ready to Move pamphlet

   Under 375.213, a second pamphlet is also required to be furnished to the shipper.

3. Written estimate

   Under 375.401 through 375.411, a written estimate (binding or non-binding) is required for every interstate move. It must be itemized, dated, and signed.

4. Order for Service

   Under 375.501, the mover must prepare an Order for Service for every shipment, including agreed dates, services, and charges.

5. Bill of Lading

   Under 375.505, a Bill of Lading is required for every shipment, including the carrier identification, shipper information, charges, and limits of liability.

6. Inventory

   Under 375.511, a written inventory of the household goods is required.

7. Arbitration program

   Under 375.211, the mover must participate in an arbitration program for claims under a specified amount and disclose the program to the shipper.

8. Pickup and delivery date notification

   Under 375.515 and related sections, the mover must provide accurate pickup and delivery date estimates and notification of delays.

FMCSA HHG Tariff and rate documentation

Movers must maintain a tariff that establishes the charges for services. The tariff is the basis for the estimates and the final bill. Under 49 CFR 375.205, the mover must make the tariff available for inspection. Audit findings frequently involve estimates that did not match the tariff, or charges on the Bill of Lading that did not match the estimate.

Cargo liability and valuation

HHG carriers must offer two valuation options under 375.701 through 375.709:

• Released value of 60 cents per pound per article (default, no extra cost)
• Full value protection (extra cost, covers actual repair, replacement, or cash settlement)

The mover must disclose both options in writing and the shipper must make an affirmative election. Missing the election or failing to disclose the options is a frequent audit finding.

Claims handling

Under 49 CFR Part 370, HHG movers must handle claims within statutory timeframes: acknowledge within 30 days, pay or deny within 120 days. The audit reviews the claims log and the timeliness of responses.

Common HHG audit findings

• Your Rights and Responsibilities pamphlet not provided or not documented
• Written estimate not provided or signed
• Bill of Lading missing required disclosures
• Inventory not prepared or not signed by the shipper
• Valuation election missing
• Arbitration program not disclosed
• Standard motor carrier compliance gaps: DQ files, drug program, ELD, maintenance, accident register

Operating authority distinctions

HHG movers operate under MC HHG authority -- separate from general freight authority. The application is different, the broker authority is different, and the consumer protection rules in Part 375 apply only to HHG carriers. A carrier with property authority cannot move interstate household goods. A carrier with HHG authority can move HHG and general freight.

Local vs interstate

Intrastate HHG moves are regulated by state public utility commissions, not FMCSA. Many local movers operate intrastate only and are not subject to the federal Part 375 rules -- but if they ever cross a state line, FMCSA applies. Misclassifying a long-distance move as intrastate is a frequent issue.

Practical setup for an HHG new entrant

• USDOT, MC HHG, BOC-3, UCR, MCS-150
• $750,000 liability with BMC-91 + HHG cargo coverage
• FMCSA Your Rights and Responsibilities and Ready to Move pamphlets printed and distributed
• Written estimate template (binding and non-binding versions)
• Order for Service and Bill of Lading templates
• Inventory forms
• Valuation disclosure and election forms
• Tariff document
• Arbitration program enrollment and disclosure
• Standard motor carrier compliance: DQ files, drug program, written policies, ELD, maintenance, accident register