Carrier Onboarding Exceptions: Who Owns the Gap and What Closes It

Write the exception as the fact that is missing

“Packet incomplete” cannot be closed by anyone. An illustrative entry, “No independent confirmation that the dispatch number 555-0142 belongs to the carrier on the packet” can. State the carrier, USDOT number, the field or document concerned, the source you checked and the date, so the exception still makes sense to someone who did not open it.

Give each exception one owner and one deadline tied to the load. Several exceptions on one carrier stay separate: a W-9 that arrives does not close an unanswered phone question, and the reverse is also true. A spreadsheet or review system works if it keeps the open item visible until someone records what closed it, as the carrier review log guide describes.

A document that has not arrived

Recommended: ask for the specific document and say which fact it will establish. A certificate of insurance establishes what an issuer stated; FMCSA warns that insurance certificates can be fraudulent, so the coverage question stays open until an independently established insurer or agent confirms it for the shipment. An authority letter or screenshot is a copy; the current public record is the check.

Expect some legitimate mismatches. The IRS instructions for Form W-9 say a disregarded entity, such as a single-member LLC, reports its owner’s name on line 1 and the business name on line 2. A W-9 headed by a person’s name is therefore not, on its own, evidence of a different company. Compare line 2 and the TIN holder against the legal entity on the packet, and ask the carrier when the relationship is unclear.

If your brokerage files information returns, the IRS TIN Matching service can check a name and TIN combination before filing. It is limited to payers and their authorized agents listed in the IRS Payer Account File, so it is not available to every brokerage.

Sources: FMCSA: Broker and carrier fraud and identity theft; IRS: Instructions for the Requester of Form W-9 (Rev. March 2024); IRS: Taxpayer Identification Number (TIN) Matching

A callback that did not connect

FMCSA tells brokers and carriers to compare a supplied phone number with SAFER and, when they differ, to call the number posted in SAFER. Where SAFER shows no phone number, the agency’s guidance is to consider not contracting until the transaction can be confirmed as valid. A callback that went to voicemail has confirmed nothing yet.

Recommended: record the number dialed, where it came from, the time and the result. Retry the SAFER-listed number or a contact your business established before the request; do not let the newly supplied number confirm itself. If the carrier says its SAFER number is out of date, the fix is an MCS-150 update with FMCSA, and the guide to a changed phone number covers how to treat the period before the record catches up.

Sources: FMCSA: Broker and carrier fraud and identity theft; FMCSA registration updates

Two sources that disagree

Record both values, their sources and their dates before choosing one. A packet address that differs from SAFER may be a recent move not yet filed. FMCSA’s insurance filing page cautions that the name and address in pre-registration filings, such as with a secretary of state, must match the authority application exactly, and that any deviation delays the grant. A difference can therefore have an ordinary cause, but it still needs an explanation tied to this carrier.

Close the exception with the fact that resolves it, for example the current authority record that supports the proposed operation, or the carrier’s confirmation through an established contact that the new address is its own. The guide on conflicting FMCSA records works through comparing field definitions and dates.

Sources: FMCSA: Insurance filing requirements; FMCSA: Company Snapshot

A request to approve despite policy

A minimum time in business, a required document or an insurance limit above the federal minimum is a brokerage rule, not a federal requirement. Recommended: let only a named person grant an override, and record what they relied on, the scope (one load, one lane or a period) and what must be rechecked before the next load. For a carrier with short public history, the new-carrier guide separates what can be verified now from what simply does not exist yet.

Do not convert an override into a general approval. An exception granted for a dry van load of low-value freight says nothing about a refrigerated or high-value load next week.

Close it with evidence, or close it as declined

Useful closing outcomes describe the work: confirmed through the SAFER-listed number on a stated date, coverage confirmed by the issuing agent for the stated shipment, source difference explained by a pending MCS-150 update, override granted by a named manager for one load, or declined because the fact could not be established. Keep the original observation beside the outcome.

Under 49 CFR 371.3, a broker must keep a record of each transaction, including the originating carrier’s name, address and registration number, for three years, and each party to a brokered transaction may review it. That rule does not prescribe an onboarding file, but an exception record that names the carrier and the evidence fits alongside it. If a gap looks like impersonation rather than paperwork, switch to the identity-theft response steps instead of continuing onboarding.

Sources: 49 CFR 371.3: records kept by brokers; FMCSA: Broker and carrier fraud and identity theft