Motus: Fix or Frustration?
Has the new MOTUS system from the FMCSA improved things or just added difficulty and frustration? In today's episode Ben and Ray tackle this challenging, and often boring, topic with their traditional lighthearted approach and unpack the most relevant and impactful changes with as much humor as possible.
They break down the new authority structure and terminology, discuss the underlying legal and regulatory framework, and look ahead at what the future holds for DOT and MC numbers. Grab your coffee and join us for the fun!
Full transcript
A complete written record of this episode.
Raymond Moss: Right, so what are we talking about today, Ben?
Ben Curtis: Boy, we got a good one, Ray. We have been queuing
Raymond Moss: Yeah.
Ben Curtis: This up for weeks now and the time has finally come. We're talking about MOTUS.
Raymond Moss: Man, well, if we're talking about MOTUS, I will let you know that it's recommended, if possible, that higher screen resolutions, such as ten twenty-four by seven sixty-eight or eight hundred by six hundred, be used to view the snapshot data. Otherwise, it'll be necessary to scroll vertically or horizontally in order to view the data tables. Also, because of the way HTML tables are implemented, the columns may word wrap at lower resolutions, causing the data to be more difficult to comprehend.
Ben Curtis: Well, God forbid the content be more difficult to comprehend.
Raymond Moss: Yeah. So that wasn't actually for MOTUS.
Ben Curtis: Wow, I haven't heard those screen resolutions talked about in some time.
Raymond Moss: It has been a while. I do remember back when I was
Ben Curtis: So where did you find that? Did you go dig that out of the archive?
Raymond Moss: I did not dig that out of the archives. I simply read one of the opening lines on the SAFER Help website from back in May. May 13
Ben Curtis: Of this year?
Raymond Moss: Of this year of 2026. Because let me just point out here that SAFER,
Ben Curtis: Boy.
Raymond Moss: Which is what everybody in our world, everybody in transportation, everybody in trucking relied upon up until May 13, 2026. Because what happened on May 14, 2026? MOTUS launched.
Ben Curtis: Yes. Talk about like we should cue ominous music right there. MOTUS launched.
Raymond Moss: Yeah.
Ben Curtis: This battle
Raymond Moss: Ha ha.
Ben Curtis: Station is now fully operational.
Raymond Moss: Yeah, that is exactly the case.
Ben Curtis: It did create a lot of chaos for a lot of people when that came online.
Raymond Moss: It absolutely did. Before we go any further though, let me just tell everyone, generally speaking, why we are here.
Ben Curtis: Yeah, good idea.
Raymond Moss: All right. Here we go. Welcome to the podcast that accompanies the DOT analysis platform, where we discuss real time trends in the truck insurance market and explore answers to the questions that you are not allowed to ask. I'm Ray.
Ben Curtis: And I'm Ben, and this is the Inside Lane.
Raymond Moss: MOTUS launched on May 14, 2026. I'm sure everyone heard, everyone is aware, it really touched a lot of people's lives. and some people really are asking the question, why did this happen?
Ben Curtis: Yeah, at this point, Ray, if you're not aware, you definitely are living under a rock.
Raymond Moss: Or you're not in transportation for real.
Ben Curtis: Well yeah, right. Yeah, it has impacted everybody's lives to say the least. in
Raymond Moss: Right.
Ben Curtis: Some pretty big ways. So we have been queuing up for this conversation for quite some time. We've been excited to talk about it. We're excited to talk about everything, let's be honest. Whether it's exciting or not.
Raymond Moss: We are a little weird that way. I think the question was asked in the office the other day, why is this so fun? This shouldn't be really that much fun, but for some reason it is.
Ben Curtis: You know, but it's it's what you make of it. So hopefully we are able to have some fun having this conversation. We still bring some lightheartedness to it because boy, it can get a little dry, I will be honest.
Raymond Moss: Yeah.
Ben Curtis: I think we're gonna try and skip over some of the dry parts and make this a little more interesting, but we'll see how that goes. In any case,
Raymond Moss: Yeah.
Ben Curtis: It has been a task to boy, what is even the right way to say it? To untangle. The web of confusion, misunderstanding, conflated terms. I mean, you could throw a whole litany of descriptors on
Raymond Moss: Yeah.
Ben Curtis: This. It has been quite the undertaking over the past several weeks here of trying to untangle all of that and make sense of this thing that we now call MOTUS, right?
Raymond Moss: Right. And just to be clear, it's something MOTUS and previously SAFER has a daily implication for motor carriers that are
Ben Curtis: Right.
Raymond Moss: The lifeblood of our economy. I mean, how many times did people realize that, especially even back in twenty twenty when everything was shut down? But trucking was never shut down because you have to get things from point A to point B. And so this
Ben Curtis: Right. Yep.
Raymond Moss: Is a linchpin of literally... this is not an understatement. It's a linchpin of the entire economy.
Ben Curtis: Yep. Okay. So premise to kind of start out our conversation here. Help me out with this a little bit. I definitely don't want to spend the podcast doing a history lesson. I
Raymond Moss: Right.
Ben Curtis: We tried, we can't even liven that up. However, I think there's some confusion, and even I wasn't sure when MOTUS actually got launched here, what things were fundamentally changing about the data, the legal structure, the underlying bedrock of how the system actually operates versus it just being semantic or system changes, system updates, technology updates, UI changes. And we were talking about this a little bit. So fill me in here, fill our listeners in on the whole thing, a little bit of the history that there weren't actually legislative changes that were correlated with MOTUS. Is that right?
Raymond Moss: Well, let me I can't you can't even quite say that because yeah, there were legislative changes, but not in the time frame that everyone expects. There nothing there's no new legislation.
Ben Curtis: Yeah, at in May of this year.
Raymond Moss: Right. There's no new legislation, but yet a whole bunch of stuff changed. So the question is why? And you're right, I don't wanna do go back all in history and go through things. I was gonna say let me give a ten thousand foot overview, but actually let me give like a hundred thousand foot overview, okay? So
Ben Curtis: Okay.
Raymond Moss: There was the Interstate Commerce Commission. Back from nineteen thirty-five. I'm not gonna say anything more about
Ben Curtis: The ICC.
Raymond Moss: It. Yeah, I'm not gonna say anything more about it than that, except to say that it ended and was abolished in nineteen ninety-five, okay?
Ben Curtis: Okay, well, but the what is the key with the ICC though, right? That's where the traditional authority types originated.
Raymond Moss: That yeah, that is where the correct. So that's where you had the idea that the government, the federal government, was going to regulate the interstate commerce of of motor carriers going across border, carrying other people's stuff across borders. So you had a common and a contract and a broker authority. Okay, that's where the whole idea started. You get to nineteen ninety five and they get rid of the ICC. Then they get this idea that you know what, we need to go to a unified carrier registration system. And we need that in place by 2005. And we better make sure that by 2007, I think it was January 1st, 2007, Congress set the hard deadline to just simplify these authority types. Well,
Ben Curtis: Mm-hmm.
Raymond Moss: Again, I'm being so brief in this, but then there's another act that's passed in 2012 that simplifies. And I shouldn't even say the word simplifies, but then redefines what it means to have an authority. Okay. And so instead of having common contract and broker authority and all of these other little characteristics about a motor carrier, they put it into really I'd say it's like thirteen. I think it's thirteen different authority types. But in twenty twelve, when that legislation passed, we're still in this unified carrier registration system. And we're using what everyone is familiar with inside SAFER. And they tried to cram the new legislative and regulatory reality into the old data structure. And it just didn't work. And so what
Ben Curtis: Okay.
Raymond Moss: So one more statement, it's this what happened with MOTUS launching on May 14th of 2026 was essentially the FMCSA. Bringing the data structure up to speed so that it actually matched the legal and regulatory framework from the past decade.
Ben Curtis: That is a beautiful statement. I think that really snapshots the essence of what we're trying to what we want to discuss today.
Raymond Moss: Right. So forget all of the history stuff because really this is about MOTUS is about the government being so slow to implement legislation passed over a decade ago because of the complexity
Ben Curtis: Yeah.
Raymond Moss: Of the data.
Ben Curtis: So MOTUS did quote unquote change a lot of things. Like people's daily life changed. The portal that they went to log in changed. The way the data is represented and a lot of the communication, the some of the verbiage that's used, a lot
Raymond Moss: Yeah.
Ben Curtis: Of the UI as we would refer to it as changed, but nothing fundamentally changed with MOTUS. Like you just made that statement, it brought things up to speed.
Raymond Moss: Yeah. MOTUS actually
Ben Curtis: With the regulatory system that's been in place since two thousand twelve.
Raymond Moss: I cringe to say this because it sounds wrong, but MOTUS actually clarified the regulatory reality that has existed for over a decade. But we
Ben Curtis: Okay. So
Raymond Moss: Lived so long in the broken data structure in SAFER and UCR that going to MOTUS feels like it's all new, but really
Ben Curtis: Okay, so let me jump in here. Not to downplay the absolutely traumatic experience that many have gone through with their filing not getting posted or issues with their filing and all of
Raymond Moss: Right.
Ben Curtis: The chaos that interjected. But all of that being said, you're actually acknowledging that MOTUS may have made some fundamental improvements to the data structure. Alright, is there
Raymond Moss: I—
Ben Curtis: Is there a glimmer of the government doing something right in there?
Raymond Moss: Well, you have to layer on the fact that they did it a decade and a half later. So I don't know if you can say they did it right, but yeah.
Ben Curtis: All right. So it's like showing up to your kid's tenth birthday party when they're twenty five.
Raymond Moss: That's exactly what just happened. And but they brought a really good gift. They got G.I. Joe and Toy Story. They got really good stuff. So happy birthday. You turned ten. You just got there
Ben Curtis: Yeah. Okay.
Raymond Moss: Late.
Ben Curtis: All right. So with that is the setup though. That's great. Our goal here today is to focus mostly on that data piece of the changes that MOTUS helped with.
Raymond Moss: And how it filters down to the actual reality of insurers, producers that are out there, the motor carriers, and how everyone looks at the data, because that's what matters. Like I all the semantics of the back end and the history,
Ben Curtis: Yeah. Right.
Raymond Moss: It's only fun when you're a freak like me or you or other people on our team. It really doesn't matter if you're on the front lines of the industry as a producer
Ben Curtis: Sure.
Raymond Moss: Or an underwriter. We that's what we're gonna talk about today. What actually matters to those people in the industry?
Ben Curtis: Right. Because our data team
Raymond Moss: On the daily.
Ben Curtis: Has done a ton of work in the background, the data team at DOT analysis, in order to weave through or navigate through this web and connect all of the data points and figure out how that correlates to historical data and all of that stuff. The idea is not
Raymond Moss: Right.
Ben Curtis: To just talk about all of that unnecessarily, but like you said, to actually pull out of that the impactful
Raymond Moss: What matters is
Ben Curtis: Yeah, the things that actually make a difference that you really need to know because it's actually gonna affect how you make decisions or how
Raymond Moss: Right.
Ben Curtis: You communicate things, how you understand the practical landscape that we're operating in. Okay.
Raymond Moss: Yeah. Right.
Ben Curtis: So with that as our backdrop, when it comes to the data structure, the practical data structure, updates or changes or implications to the authority types and the definitions around them is the most significant thing we want to focus on today, right?
Raymond Moss: Yeah, there's so much that you could put under the layer of MOTUS changes.
Ben Curtis: So throughout this, what I'm gonna try and do is continue to press us to make sure that we define terms really carefully. Cause that's a huge
Raymond Moss: Yeah.
Ben Curtis: Thing of importance to us, right? In fact, we showed a couple
Raymond Moss: Absolutely.
Ben Curtis: Weeks ago on this podcast, we showed our glossary of terms that we put on the website. And I know that we're still working on updating some of those. A bunch of the ones we talk about today are gonna get added into that so that we can try and help continue to bring clarity there. But a conversation can not only be pointless, but can actually be misleading if we don't really carefully define our terms. Because otherwise,
Raymond Moss: Yeah, words really matter.
Ben Curtis: Yeah, man. And so I'm gonna take the role of explain it to me like I'm five in this discussion, so that we can try to bring insane clarity to a really confusing topic. That's what we always try and do, not only within our DOT analysis platform, but on this podcast, the goal is to bring clarity where there's confusion and misunderstanding, right? So
Raymond Moss: Exactly. Absolutely.
Ben Curtis: So that being said, let's just start with authority. Because of the data structure in the past and the way some terms got used, let's just start with defining what authority, not authority types, what does authority actually mean and how does that differentiate from Motor carriers who have an authority versus motor carriers who are operating without an authority.
Raymond Moss: Whew, that's a doozy just even to define that. Okay. So I'd say conceptually
Ben Curtis: Mm-hmm.
Raymond Moss: Authority is the authorization to haul something over state lines.
Ben Curtis: Okay. So let me just restate it back to you and that'll maybe help clarify it. It's the authorization from the federal government. The whole point of why it's coming from the federal government is because it's not within a state. So we are this is an interstate thing, right? Is that safe to say? So it's
Raymond Moss: Correct. Yep. Yep. So it's gotta be something to do with crossing state lines.
Ben Curtis: And it's hauling something. You said something. So I assume what you mean is it could be goods, it could be passengers, could
Raymond Moss: People. Yeah.
Ben Curtis: Be of yeah, not limited to that. Those are some of the different types that we'll get into, but it's hauling something, people or goods, across state lines. Therefore it's the federal authorization to do that. It's federally regulated since an individual state can't regulate it.
Raymond Moss: I'd say yes, except for this reality, is that it's not just necessarily the hauling of that, but you're participating in the business transaction of hauling something. Because what is a broker and what is a freight forwarder?
Ben Curtis: Yeah, right.
Raymond Moss: They're not in the truck, but they're participating
Ben Curtis: Right.
Raymond Moss: In the business transaction of getting the goods or the people across the state line. That's what the government is regulating.
Ben Curtis: Okay, so let's restate that then. The authorization to be involved in the commerce of or the for-hire commerce of moving people, goods, or some type of product across state lines.
Raymond Moss: There you go.
Ben Curtis: Okay, so that's that's what authority actually means. Here's the reason why that's important to define is because as you mentioned, with the 1995 bill that got passed and the change in some of that structure, the old the legacy version that existed since what 1935,
Raymond Moss: Yeah, yeah.
Ben Curtis: Common contract, and broker didn't really apply anymore. But that was the data structure that was in place. And therefore, the new authority structures that actually got defined kind of got jammed into that old data, or let maybe the it's the other way around. The old data structure got jammed into the new authority types and it conflated some things that don't correspond with authority.
Raymond Moss: Right. But could
Ben Curtis: So
Raymond Moss: At first blush appear to correlate really well.
Ben Curtis: Yeah. So in that common contract and broker authority, even though the common and contract technically went away and it became motor carrier of these various goods or various things.
Raymond Moss: Things. Yeah.
Ben Curtis: Because that data structure didn't exist, it became that the operation type, which there's a whole list of operation
Raymond Moss: Yeah.
Ben Curtis: Types you could be categorized as. The operation type became a modifier on the previous common or contract authority type that then was the square peg
Raymond Moss: Even though operation isn't an authority.
Ben Curtis: Right. But it's it as a modifier on a previous authority type of contract or common became the square peg that got jammed into that round hole of the new authority type that the legislation and then the therefore the legal structure
Raymond Moss: Right.
Ben Curtis: Actually supported.
Raymond Moss: Which is what happened over a decade ago with legislation in ninety five, two thousand five, and in twenty twelve. And if you like, can I pull up SAFER here real quick? 'Cause I just want to show
Ben Curtis: Yeah.
Raymond Moss: Our audience here the example of what we're talking about. So for example here,
Ben Curtis: Yeah, this is great.
Raymond Moss: We have operation classification. And in the SAFER system, in the technology that existed, there was the ability to mark an operation classification of private passenger bus, private property, authorized for hire, but then you have like US mail, federal government, state government, like there's all these other operation types. It's not an authority.
Ben Curtis: Right. So that's what's confusing about this is conflating different things because some of these were modifiers like passenger carrier there. That was an operation modifier that got used to define a legal authority type. But some of these
Raymond Moss: Yeah.
Ben Curtis: Other modifiers in here did not do not correspond to an authority type. So it just obfuscated the whole thing, made it super confusing and murky what
Raymond Moss: Right.
Ben Curtis: Actually this means regarding authorities.
Raymond Moss: It yeah. It absolutely
Ben Curtis: And so
Raymond Moss: Did.
Ben Curtis: When you said that MOTUS actually clarifies some things, why don't we jump to this for a second then? What MOTUS actually clarified is that it actually now connected the data structure to allow for the correct terms to actually
Raymond Moss: Yeah.
Ben Curtis: Get used to match up with the true authority types that have actually been legislatively and legally underpinning this whole system for the last twelve or fifteen years here.
Raymond Moss: Yeah, yeah, absolutely. It did. So let me show that.
Ben Curtis: All right, so we consolidated those. Yeah, you wanna pull that up?
Raymond Moss: So here are thirteen different actual authorities. So forget common contract and broker and all the little other modifiers in the data structure that SAFER used to tell you in order to figure out what someone was authorized to do in their interstate commerce. Forget all that and look at these thirteen individual authorities. Let me just I'm just gonna read them all fast. We got broker,
Ben Curtis: Okay. All right, sure.
Raymond Moss: Broker of household goods. Broker of property except household goods, motor carrier of household goods, motor carrier of property except household goods, motor carrier of passengers, freight forwarder of household goods, freight forwarder of property except household goods, enterprise motor carrier of household goods, enterprise motor carrier of property except household goods, Mexico-Domiciled Motor Carrier of Household Goods, Mexico-Domiciled Motor Carrier of Property Except Household Goods, and Emergency Temporary Authority. my gosh.
Ben Curtis: Yeah.
Raymond Moss: Could you name them anything more weird? But at least
Ben Curtis: Right.
Raymond Moss: It's
Ben Curtis: Pull the pencil out of my eye here as I just stabbed myself while you're reading that list. Yeah. So
Raymond Moss: Yeah.
Ben Curtis: Ridiculous. Well I say ridiculous. Just confusing, right? I mean, as long as you're looking at it on an eight hundred by eight hundred monitor, I guess you're okay though, right?
Raymond Moss: Yeah, that's right. But here's the thing. Even though that's
Ben Curtis: So
Raymond Moss: A mouthful of words, it actually is closer to the reality of the legal and regulatory framework that's been in place for years now.
Ben Curtis: Right. So what you need is a lens to look at this that actually does make it understandable. And that's what we've sought to do. So this is the list. This is the actual list of real authority types that exist within the new data structure now and that match the legal regulatory framework within MOTUS. So let's look at our format for displaying this that actually makes this more understandable.
Raymond Moss: The best way to see that is if we are in Market Explorer and we have a filter in.
Ben Curtis: Okay. This is we're on the DOT analysis platform now.
Raymond Moss: Yes, we're on the DOT analysis platform. I opened up Market Explorer, and in Market Explorer, you apply all sorts of filters, but one of them is authority type. And in the past, you would look at authority type and you had common and contract
Ben Curtis: Common.
Raymond Moss: And broker. And then you could add modifiers for passenger or household goods and yeah, all
Ben Curtis: Operation types are things. Yeah, right.
Raymond Moss: That kind of stuff. But now we are following and I believe make it very simple to show that there are these different variations that we just saw on the list. But look, look how we organize these. You're a broker.
Ben Curtis: Okay, yeah. So let me just to set this up as we go into this. You just read the list. I fell asleep, but you read the list of the 13
Raymond Moss: Right.
Ben Curtis: Authority types. So what you're gonna go through now, this is the synthesis of those 13 types, but broken out into a format that lets you build it out step by step. Is that a good way to set this up?
Raymond Moss: Correct, because everyone, everyone's pretty broad, but I should say most people, most people think of it this way. They think, are you a motor carrier? are you a broker? are you a freight forwarder? And they start with that in their mind. And so they're thinking in that terminology first. And then they say, like for example, you're a motor carrier of property, excluding household goods, or they say, You're a motor carrier of household goods. So what we
Ben Curtis: Right. So go ahead and show what we're seeing on the screen here because I see that matches that. So we have those initial what are those initial three headers we've got here? It looks like broker, motor carrier, and freight forwarder. Those are the three entry points through which you're going to look at authority. Is that the right way to say that? You have three first doors. So there's if there's a
Raymond Moss: Yeah, that's right. Yeah, three first doors to look through.
Ben Curtis: If there's a door that goes into a hallway and then there's multiple other doors in that hallway, the first three doors, you're either a broker, a motor carrier, or a freight forwarder. Okay.
Raymond Moss: Right. And so we matched up the confusion of the regulatory apparatus and all these stupid phraseology that the government used
Ben Curtis: Yeah.
Raymond Moss: And simplified that. And we love to do that. And believe me.
Ben Curtis: All right. So if we just pause on that piece of it for a second, one thing I noticed broker authority is something people were familiar with. That's still here. Common contract are not here anymore. I see motor carrier. It appears that most of what people traditionally thought of as common or contract are both kind of rolled up under this structure that we're gonna see through the door of motor carrier. Is that right?
Raymond Moss: Right. Yeah, that's right. So
Ben Curtis: And then the last one, hold on, before we go into that one, sorry, one more thing. Freight forwarder, another term that people are very familiar with. And this one is super weird because it technically didn't exist within the data under the authority structure, even though legally it is an authority type. Is that right?
Raymond Moss: Right. Yeah, that's right. And how did the government do this? When you remember the square peg through the round hole, what they did in the past is they would say, Well, you don't have an MC number, you have an FF number. So that's your authority. And so you could see if someone had a freight forwarder authority to see if they had an FF number and if that was active, but it was they didn't literally say in the data structure of SAFER that you had a freight forwarder authority. And they certainly didn't say you had a freight forwarder of household goods or a freight forwarder of property except household goods. That was never laid out in the structure of the data. So you couldn't really see it. You kinda could, but you couldn't.
Ben Curtis: Okay, so what goes along with that then is these authority types have always been thought of underneath the MC number designation, right?
Raymond Moss: Yes. Yep.
Ben Curtis: So are MC numbers being replaced by DOT numbers?
Raymond Moss: I will try to answer that by starting off with this statement. The government is playing the long game. And I would conjecture that they are trying real hard to get rid of the MC number because it's kind of a relic of times past.
Ben Curtis: I bet people are gonna freak out if they just heard MC numbers are going away.
Raymond Moss: They would absolutely because there's people that are so reliant on the understanding of the past and how the structure of data flowed through.
Ben Curtis: Yeah. I think I saw somewhere in the FMCSA documentation that they made the statement that DOT numbers are not replacing MC numbers. Did you see something about that too?
Raymond Moss: Yeah, I did. And then did you see the sentence after that?
Ben Curtis: Yeah. Yeah, I think it said something to the effect of we've just issued DOT numbers to everyone and we may be phasing out the MC numbers.
Raymond Moss: Right. But that's been like a theme for literally years and years and years. People have talked about that.
Ben Curtis: Yeah.
Raymond Moss: They've now, with MOTUS, put in place the data structure to be able to actually do that. So they're going in that direction. I can't say that they are, but they're going in that direction.
Ben Curtis: Yep. Alright, I have a perfect a perfect illustration for this point for you, okay? You ready? All right, I'd hang on just a second though. I gotta bring you something, okay?
Raymond Moss: Okay. This is your water.
Ben Curtis: Yeah, I just wanted you to have that.
Raymond Moss: Thank you.
Ben Curtis: Yeah, you're welcome.
Raymond Moss: It looks like you drank half of it.
Ben Curtis: That's beside the point.
Raymond Moss: Okay. So this still has something to do with MC numbers, right?
Ben Curtis: Yeah.
Raymond Moss: Are you trying to say I shouldn't be drinking my coffee?
Ben Curtis: No, not at all. I would never try and replace your coffee with water. Are you kidding me? That'd be crazy.
Raymond Moss: That's good because I really need a lot of coffee.
Ben Curtis: Hang on. One more thing. Hang on a second. Right. now I see you got that fancy water there. I don't there's just there's really no need for this anymore, right?
Raymond Moss: That's my coffee.
Ben Curtis: Yeah, important that you know though, I did not replace your coffee with water. I just now that you have that water, obviously there's there's no need for you to
Raymond Moss: Who
Ben Curtis: Hang on to this old coffee.
Raymond Moss: So what you're trying to say is my MC number is not gone.
Ben Curtis: It's not replaced. We're not replacing it with a DOT number. It's just here's a fancy DOT number for you and you might not need your MC number anymore.
Raymond Moss: Well I definitely need my coffee.
Ben Curtis: Okay. All right. Well we'll fix that. Let me take care of that for ya. And then yeah, there you go. Perfect. All right.
Raymond Moss: That's better. That's better.
Ben Curtis: So yeah, silly representation. I don't know honestly why, other than the fact that, like we said, people would probably freak out because they're so used to things operating the way that they always operate that if they said MC numbers are going away, people would lose their minds. It's not gonna just like we're saying MOTUS didn't actually change something fundamentally, it just affected the way that they're messaging things and the way the data works. The same general principle is true with the phase out of MC numbers is it's not actually gonna change the way you're doing your operation, your legal structure, any of that, any of that stuff. It's more mostly semantics, but of course, to avoid the rapid sudden change or freaking people out, they message it as we're not replacing the MC number with a DOT.
Raymond Moss: That is a whole lot of reality about the MC number.
Ben Curtis: Okay, so maybe too much of an explanation. I don't know. But as we set up this whole context here, so we're digging into, we're going through these hallways, let's call them that, or doorways of these authority types. So we got broker, motor carrier, freight forwarder. Now we read that list of the 13. If we look at this and we look at all the subcategories or the other doors down these hallways behind each of these, this is what actually fills out each of the legal authority types that exist. Is that right?
Raymond Moss: Right.
Ben Curtis: How do you wanna
Raymond Moss: Yeah. People want to not only see what authority they have now, maybe someone has one of these authorities and another one is pending or they had it previously, so it's inactive. I mean, there's all sorts of real world use cases for why you would want to know
Ben Curtis: Boy. Yeah.
Raymond Moss: The authority status of a motor carrier. And you can no longer say, do you have a common authority because it was kind of a catch-all, right? You got these long sentences where you
Ben Curtis: Right.
Raymond Moss: Do you have authority? Well, which kind of authority? Well I have a motor carrier of property except household goods and I have a motor carrier of household goods. So there's all sorts of different ways to look at this, but yeah you look at those first three doors broker, motor carrier, freight forwarder, and then you ask what modifier gets tacked on after that. I'm a motor carrier of passengers. Why? 'Cause I have a whole bunch of buses. You say, I'm a motor
Ben Curtis: Yep. Right. Yep.
Raymond Moss: Carrier of property, except household goods, you know. Or you say, Hey, I'm a motor carrier of household goods, 'cause I'm going back and forth right from people's front door and helping literally move their stuff.
Ben Curtis: Right. So lest we give the government too much credit for clarifying things, they also at the same time made some things way more confusing. Did you see
Raymond Moss: Right.
Ben Curtis: The new update to DOT numbers is going to be letter, what they're calling suffixes? So it's tacked on to the end of the DOT number. Did you see that? Do you have that document
Raymond Moss: Yeah, I did.
Ben Curtis: To pull up here?
Raymond Moss: I did see that document. It is posted right on the FMCSA's website. It is MOTUS US DOT number suffixes. And if I click on that, I get a
Ben Curtis: Boy.
Raymond Moss: Really not clarifying document that mixes unfortunately, it mixes the concept of operation and entity and registration with the authority again.
Ben Curtis: Yeah. So all right, can you for starting out, like can you scroll down on that document? Cause on the bottom of it, yeah, right here. So this shows how it shows up as a suffix. So you got your traditional DOT number, and then right at the end of that is just tacked on a letter suffix. And it could be one letter or multiple combined letters. So that just adds to the confusion as well. But yes, the challenge is a lot of the actual verbiage on the FMCSA site and in their Q&A section, if you go look at it, it'll describe — I don't know if this document actually says it or not, but a lot of their stuff describes the suffix as describing the authority of the motor carrier. And so this is what you were alluding to, saying this merges stuff is the reality is if you scroll back up and look at what those letters designate, some of them, like property carrier operating authority, that is an authority. In fact, a number of these, what did we count? Five or six of these, actually are specific authorities. And they correlate to those 13 authority types we just covered. In that case, having that letter designator will give at least some insight into the type of authority that you have. However, not all of these letters represent authorities. Some of them are what we would call more accurately an operation type, right? An operation or a class of.
Raymond Moss: Right. Registration.
Ben Curtis: Registration, classification, yes, something like that. So for example, R, the last one in the list, intrastate carrier. That is not an authority. By definition,
Raymond Moss: Right.
Ben Curtis: You do not need an authority to operate intrastate, correct?
Raymond Moss: That is correct.
Ben Curtis: So having an R after your name, after your DOT number, does not mean that that is your authority type. That is definitionally not an authority.
Raymond Moss: And let me also throw this out at everyone as well, is that these suffixes are only being given out to new DOT numbers right now. So if you go into MOTUS,
Ben Curtis: Right now. Yeah.
Raymond Moss: Yeah, if you go into MOTUS and you put in a DOT number that existed five years ago or whatever, you're not going to see any kind of suffix, regardless of what their operation or authority type is. If
Ben Curtis: Right. That doesn't mean there's a problem, because once again, this is only informative. It's
Raymond Moss: Right.
Ben Curtis: Not actually an authorization in and of itself. It's just informative
Raymond Moss: This is
Ben Curtis: In trying to connect the dots in the
Raymond Moss: And it's lining up
Ben Curtis: Data.
Raymond Moss: It's lining up all of the prerequisites that are necessary for when if it happens they do get rid of MC numbers.
Ben Curtis: The MC number goes away. Yes, yes.
Raymond Moss: Right. So it is lining up all of those prerequisites so that it is possible to get rid of those MC numbers, another unique identifier that they're saying, We have DOT numbers. Why do we need another unique identifier? Let's get rid of this number. That's why that's happening.
Ben Curtis: Yep. Okay, so a couple of things I wanted to clarify here. One is they may go back over time and apply these to previous DOTs. So it doesn't mean that your DOT will never get this.
Raymond Moss: That would make right.
Ben Curtis: It might. It's just right now it's only being applied explicitly to the to new, newly issued DOTs. But
Raymond Moss: To newly issued DOTs. Yeah, that's right.
Ben Curtis: Likely they will end up applying those to old ones. I don't know if that'll happen all at one time, if that'll happen gradually. We'll we'll
Raymond Moss: Yeah, who knows?
Ben Curtis: See. But Fundamentally, once again, don't freak out, it's not changing anything about your actual authority. It's just changing the way that it's displayed. It's visual only. Another point I want to
Raymond Moss: That is right.
Ben Curtis: Clarify: we said we were going to focus on practical things. So far, at least in all the documentation on this, they're saying there's not going to be a requirement to change the actual lettering on the physical lettering on any of the trucks. So just because you get this letter designation. Both retroactively and I believe new, newly issued ones, you still don't need to include that on what's printed on the trucks. It will just be a requirement to have on forms and paperwork. So nobody's gonna have to go back, at least for now what they're saying, and make any changes to that physically on equipment. So that's nice anyways.
Raymond Moss: Right. Yep. That is good, 'cause that'd be even more confusing.
Ben Curtis: Okay, so yeah, there's some things are getting clearer. It's just important to know what everything means and how to use it. If you as long as you realize
Raymond Moss: Right.
Ben Curtis: What stuff is intended for and you put it in the proper category, put it in the proper framework, then it's fine. Realizing that these suffixes are not intended to define specifically authority, it includes authority and includes other things as well. Look at it as informative in better understanding. what the authorized use or registration or operation of a specific motor carrier is. As long as you look at it that way, then it helps avoid that confusion of conflating something that is truly an authority with things that are not an authority.
Raymond Moss: Yeah, that's true. So is it safe to say it this way, that those suffixes are not exclusively indicating authority.
Ben Curtis: Right.
Raymond Moss: They are indicating different operational and registry and operation types, but they're also not encompassing all operation types, because look what it says right here: it does not have cargo tank, intermodal, or hazmat — those don't even have their own suffixes. So
Ben Curtis: Yeah, so they le they still left a bunch of stuff out. Yeah. Let's definitely not give the government too much credit here for sure.
Raymond Moss: Yeah. Yeah, that's yeah.
Ben Curtis: They didn't consult with us about what system to use for this. We are just doing our best with what we're given, and that is trying to just bring as much clarity as we can through this glass of muddy water that's in front of us. And that's the best we
Raymond Moss: So to summarize,
Ben Curtis: Can come up with.
Raymond Moss: So to summarize, let me say this. If you are looking to understand authority, there's no more common, there's no more contract, there's no more broker authority. Those things are gone. But what there are, are these
Ben Curtis: Well, let me just clarify common and contract are actually gone. Broker still exists in a certain format, and that it's actually a term that is still used in the architecture of authority.
Raymond Moss: All right, well let me try that again then. Common is gone, contract is gone, the single word broker is gone, but they still use the word broker in broker of household goods and broker of property except household goods, and
Ben Curtis: It now it must be used in conjunction with one of those two. It can't be a standalone. That's what you're saying.
Raymond Moss: That is correct. There's no such thing as a standalone broker authority. And here's the
Ben Curtis: Okay.
Raymond Moss: Other confusing part is that someone listening will say, Well, it's always been like that. You're actually it's been like that for a long time. You're right. It's just that SAFER and the government's data structure that they try to keep all these records in. didn't have the capacity and didn't have the ability to keep all of this straight. So people would just use the terms broker authority and they haul household goods. But now you can actually say broker of household goods in the system, MOTUS that is keeping the record of all these things.
Ben Curtis: Yeah. All right. So we mentioned practical implications. The other thing I think that is worth mentioning here, I know many people have already gone through the whole process of logging in, claiming their DOT. That was a big thing too, because a huge thing to make this all work in the background was the government needing to make sure they're connecting all the dots between your historical data structure that existed in the various platforms. So logging in, claiming your DOT, getting all those dots connected, the ID verification, all that stuff that's been happening. Most people have probably already done that. They're using all of that legacy data and all that link together data to pull through and now define your current existing authority or authorities. Definitely a good idea to double check that system and verify that the authority that you have assigned and that you're operating under actually matches your legal authority type and legitimate operation. Because
Raymond Moss: Right.
Ben Curtis: Of the conflated operation types, it's possible that there's an incorrect form or something that was filed at some point that's conflating the wrong operation or not accurately representing your current authority type due to a misunderstanding or a misrepresentation of your operation type in the past. Is that possible as you understand it?
Raymond Moss: Yeah, that's a good way to describe it because when the FMCSA opened up MOTUS to be able to be logged into by motor carriers, they had motor carriers claim their DOT number so that they could try to thread the needle of all of these the understanding of the authority and who the motor carrier was. And so if you haven't done that yet, and most have now at this point, you know, because that was back in May that this went live. but if you haven't, motor carriers need to do that and it's definitely something to be aware of and it's good to know why because the government was trying to take this disparate data structure and correct it so that it actually reflects the reality of the legal and regulatory framework that's been in place for a long time.
Ben Curtis: Yeah. How important is it though for motor carriers to verify that their newly listed the way their authority is listed now is actually correct and matches? Is there a possibility that they at one point
Raymond Moss: A hundred percent.
Ben Curtis: In the past filled out their operation type not realizing that was gonna now correlate to authority? And 'cause one I think
Raymond Moss: Yeah. That's actually the crux of the issue that's been happening for the last several months. And actually it led to the FMCSA publicly saying — this was only a couple of weeks after May fourteen when things went live — okay, hey, we're going to stop inactivating authorities for a certain amount of time. And they realized that there were so many people that hadn't gone through and, you know, quote unquote fixed their data, fixed their registration, that they pulled back, said, this is too operationally, on the daily, negatively impacting motor carriers — we'll stop enforcing this. And so there's still inaccurate data inside of MOTUS for motor carriers, unfortunately, you know, almost every single day. And it's hard, especially when that affects a motor carrier's operations. I mean, there's a lot of people that look at MOTUS and say, hey, should I give you a load to haul? Are you authorized? Do you have insurance? It's
Ben Curtis: Yeah, it's rough.
Raymond Moss: That is really rough. And that really can impact you if you're a motor carrier. Like literally. It's your livelihood.
Ben Curtis: All right. So here's here's one example that I wanna use. I think this is maybe a great one to understand the difference though between your previous operating type. One of the ones we talk about all the time that has a ton of confusion with it is that household goods. And now they've made it explicit by each of these operation types, calls out excluding household goods or of household goods, for they're very explicit about that now. However, historically, there's a lot of people that had operation types or cargo types on their MCS-150 marked as a carrier of household goods. And they thought, well, I haul candles for Target, and that's a household good. So I must be a household goods carrier. If that was marked as your operation type in the past, and now your authority type is listed as motor carrier of household goods, that may not actually be the appropriate authority type for your operation.
Raymond Moss: So there's two different things there that you can mark on the MCS-150 as cargo that really conflate both the idea of cargo and the idea of authority. You can literally say in your MCS-150 that you haul household goods. Well, that's a designation of authority type. And you can also put in the MCS-150 that you haul passengers. That's another authority type. And so people often confuse the two. And you need to be really clear as a motor carrier filling out your MCS-150 in the past, marking that, you know, in the detangling of all of this data that MOTUS did. Understand that marking passenger on your MCS-150 and marking household goods on your MCS-150 does not bring you up to applying for the authority for those two things. It's not the same. It's not the same. And I don't know, I don't know if I can say it any clearer than that.
Ben Curtis: Yeah. So there's two things that I'm wanting to so to I guess discuss here. One is explaining for people who might be confused about this what exactly household goods mean, and then figuring out if there's how much risk there is of because before that wasn't directly linked to what people saw as their authority type, is there
Raymond Moss: Right.
Ben Curtis: A chance that the government in their attempt to string together all these data points actually is assigning certain motor carriers with the incorrect authority type? Because in the past they thought their operation was household goods. So now
Raymond Moss: Right.
Ben Curtis: They're getting this household goods.
Raymond Moss: Right. And I've seen they have an inactive motor carrier of household goods authority because it was listed as a on their MCS-150 that they did household goods. They don't have an authority. They don't have a filing posted for it. So yeah. Does that answer that question?
Ben Curtis: Yeah, I think so. So let's just clarify for anyone who is either isn't sure or is unaware that there is so much uncertainty out there. What does household goods actually mean? It does not mean hauling candles for Target, right?
Raymond Moss: No, it does not mean that. But I know a lot of people who think, hey, I'm hauling toasters around and I'm gonna go bring them to Walmart. That's a household good. No, that is not it. That is not what household goods are. Household goods, it's a household goods mover. So it's someone that literally brings that truck right up to the front door into the driveway of a home, you know, like four walls and a roof, and you know, mom, dad, and the kids live in there, and they help you move the goods of your household into the truck and then go bring it. To your next house 'cause you moved out of state. That's a household
Ben Curtis: Right.
Raymond Moss: Goods mover.
Ben Curtis: Now, yeah, you just said out of state. Now that would involve an authority type. The classification of just household goods mover, you don't have to go out of state for that to still be classified as household goods mover. A household goods mover definitionally though is what you just said. You're loading and unloading at a personal residence and moving the goods from the personal residence. Those two things both have to be true for you to be considered a household goods mover.
Raymond Moss: And if you go across state lines, you need a motor carrier of household goods authority to do that.
Ben Curtis: An authority to do so. Right. However, if you're operating intrastate, you are still doing that operation. You are still a household goods mover. Just as an intrastate operation, you may not actually need the authority, the household goods authority to do so, but you would still
Raymond Moss: Correct.
Ben Curtis: Be classified as in your operation type as a household goods mover. That would still be an accurate description of your operation. Is that a good way to say that?
Raymond Moss: That is right. So that is a good example of why it's important to be able to see the difference between the authority type of household goods and the operation of household goods. And when
Ben Curtis: Yeah.
Raymond Moss: The government smashed those two concepts together in their old data structure, it made things very difficult to understand. And so, lest I compliment the government,
Ben Curtis: Yeah, very confusing.
Raymond Moss: I will admit they made it more possible to see in the data the difference between those two things, the operations of household goods. and the authority of household goods.
Ben Curtis: All right, so because we're on the household goods topic, just to clarify one last thing, then this also does not mean, and we specifically looked it up to verify it, this does not mean delivering household items even to a residence, like final mile delivery. It specifically excludes
Raymond Moss: Yeah.
Ben Curtis: Even the delivery of things like furniture, but from a manufacturer or retailer to a residence.
Raymond Moss: Right.
Ben Curtis: That is still not considered a household goods mover. It literally
Raymond Moss: Right, that is not.
Ben Curtis: Is the loading and unloading of property from a residence to another
Raymond Moss: To a residence.
Ben Curtis: Residence. Yes, that is the very strictly defined definition of the household goods mover.
Raymond Moss: Right.
Ben Curtis: Just amazing how complicated these are. And so then how much confusion and misunderstanding there actually is out there. And boy, if you don't define those terms well though, it is really hard to have a conversation about it. Cause someone says household goods mover and you think you're talking about the same thing, you're not talking about the same thing.
Raymond Moss: No, that is definitely true. And that concept is riddled all through this industry. Broker — what is a broker? I don't want to confuse the topic here, but just for a fun example here, you could be a broker of loads, you could be a broker of insurance, you could be a my goodness, there's a hundred different layers of both of those, right?
Ben Curtis: Yeah, so hold on, just to differentiate, because broker is one of our authority starting points here. So when you use the word
Raymond Moss: I shouldn't even have said it.
Ben Curtis: When you're using the word broker, you're not even defining authority. You're just saying in the industry at large, the word
Raymond Moss: Yeah, that's right.
Ben Curtis: Broker is like a throwaway word 'cause it can literally mean anything.
Raymond Moss: Right. If you say the word broker around here at our office, you instantly get sucked into a black hole and we don't talk to you for twenty four hours. Because it's too confusing. You have to describe it way
Ben Curtis: Yeah.
Raymond Moss: More than that.
Ben Curtis: Yeah. Yeah. It is kind of unfortunate to be honest.
Raymond Moss: Yeah, it definitely is. It's very complex.
Ben Curtis: So all right. I yeah, this has been a journey, a little bit of a ride here today. if anyone's still awake, then kudos to you. pat yourself on the back. And you know what, take the rest of the day off too. Yeah, you got our permission to do that.
Raymond Moss: That's right.
Ben Curtis: Yeah, no, thanks for hanging on. hopefully it's been clarifying and helpful. Do we have any other specific things we need to? Like we absolutely have to get into this episode here today.
Raymond Moss: I don't think so. I think this is a lot. There's so much more in MOTUS that we could unpack.
Ben Curtis: Yeah.
Raymond Moss: But this concept, I believe wholeheartedly, is the most impactful for the daily interaction of the industry. And to understand this, whether you're a producer or an underwriter or a marketer or anybody, you gotta understand this and how this terminology and this data structure has morphed throughout the years and what happened this year. with the rollout of MOTUS.
Ben Curtis: Yep. Okay. Well, if anybody has questions, definitely reach out to us, send us an email, contact us through the website, whatever on LinkedIn or wherever you find us. Be great to hear what your feedback is, what your personal experiences are with how this has been going. we do know because we've heard from quite a few people that people are having issues with incorrect data in the FMCSA database or weird glitches where like their filing requirement is wrong or their DOT number or their authority is listed as yeah, there's
Raymond Moss: Yeah, the status of their authority is active, but then it says reason, revoked, and like all sorts of
Ben Curtis: Yeah.
Raymond Moss: Different crazy things.
Ben Curtis: Unfortunately, all we can do is view that data. We can't actually fix it. We don't have a backdoor into the FMCSA database to fix that stuff. So unfortunately, we can't do anything about that. We can just look at all that data and see where those problems pop up. So we can't do anything about that. But if you have any other specific experiences with things that are interesting or questions about this. We'd love to hear what that is. We'd love to know if this is filling the need or if there's still a lot of gaps that exist out there. So definitely let us know.
Raymond Moss: All right, and until then will see you guys next time.
Ben Curtis: Have a good one.