Ongoing compliance

Staying compliant between renewals.

Most carriers lose authority to paperwork, not to bad operations. The obligations are periodic, and missing one starts a clock nobody tells you about.

Authority is a continuing permission, not a one-time grant. The Commission can act against a permit for violating a term or condition of it, and a lapsed insurance filing or an unfiled change of name is a violation of a term or condition.

The compliance work is unglamorous and repetitive, which is exactly why it gets missed. This page lists what the Commission actually expects a Colorado carrier to maintain.

Insurance

The filing that has to stay current.

Financial responsibility is a filing obligation, not merely a policy you hold. For household goods movers the insurer files the commercial auto liability policy with the Commission through its portal. A policy that lapses, or a filing that is never made, leaves the permit exposed even where coverage exists on paper.

When coverage or carrier changes, the filing has to change with it. This is the single most common cause of a compliance problem that surfaces months later at renewal.

Records

What to keep and be able to produce.

In a permit or enforcement matter, the record is largely the carrier's own paperwork. Dispatch records, bills of lading, contracts, insurance certificates, inspection reports and the permit itself are what a proceeding is built from.

Keep them for the periods the Commission and your insurer require, and keep them retrievable. A carrier that cannot produce a three-year-old bill of lading has effectively conceded the point it was being asked to prove.

Annual vehicle inspection reports
Insurance certificates and the Commission filing confirmations
Bills of lading and dispatch records
Executed contracts and written estimates for movers
The permit as issued, and every amendment

Changes

Name, location, and authority changes.

A permit is not valid for business at a location other than those designated in the application, and a mover may not do business under more than one name except as shown on the permit. A change of name or location requires written notice to the Commission, and is cleanest handled at renewal.

Adding a service class is a separate application, not an amendment to what you hold. A carrier holding household goods authority that starts carrying passengers has a new application to make.

Rates

Rates, tariffs and what the Commission expects.

The Commission prescribes rules on rates and service, and carriers file tariffs as those rules require for their class. A tariff that does not match what the carrier actually charges is a compliance problem, because the filed rate is the rate the Commission expects to see applied.

The office reviews existing filings against actual operating practice, which is a cheaper exercise than defending a complaint that a filed rate was not honored.

Common questions

Questions this office hears

Is compliance only an annual event?No. Renewal is annual, but insurance filings have to be current at all times, name and location changes require notice when they happen, and inspection requirements run on their own schedule.

Who files the insurance with the PUC?The insurer files it through the Commission's portal. The carrier's job is to make sure it happens and to keep evidence that it did.

Can I add a service without a new application?No. Each class of authority, household goods, passenger, contract, requires its own application. Operating outside the class you hold is exceeding the authority granted, which is a listed ground for Commission action.

Sources

Where this page's facts come from

Every regulatory statement above is drawn from the following, so you can check it yourself.

C.R.S. 40-10.1-502, permit requirements and renewal
C.R.S. 40-10.1-112, Commission action against a permit or certificate
C.R.S. 40-10.1-504, advertising and permit name
C.R.S. 40-10.1-106, Commission rules and rates
Colorado Public Utilities Commission, Household Goods Movers industry information