The Cargo Certificate Said $100,000. The Insurer Paid $18,400.

A broker had a load of consumer electronics — 42 pallets, laptop computers, $97,000 invoice value, Ontario, California to a distribution center in Secaucus, New Jersey. She'd vetted the carrier. MC-1247893, DOT-3567102, 26 months of authority, nothing alarming across the BASICs. She verified insurance against FMCSA's L&I system, not just the certificate. The ACORD 25 from Motor Cargo Insurance Co. showed commercial cargo coverage at $100,000 per occurrence, commodity description: "Any Commodity." She'd seen that field checked a hundred times. She moved on.

The truck dropped off tracking 38 miles from the receiver. Dispatch went to voicemail and stayed there. The trailer turned up six days later outside Amarillo, empty.

The insurer came back with $18,400.

The policy had a FAK schedule — Freight All Kinds — with electronics and computers rated as a separate commodity class. The maximum payout under that class was $18,400. The $100,000 per-occurrence limit applied to other commodities. For electronics, the ceiling was $18,400. That language didn't appear on the ACORD 25. ACORD 25 certificates don't show commodity sublimits or FAK schedules. They show the per-occurrence limit and the commodity description. "Any Commodity" described the policy form. It didn't override the sublimits built into it.

She got 19 cents on the dollar. Her shipper customer got a lawsuit.

What "Any Commodity" Actually Means

"Any Commodity" on a cargo certificate is not a guarantee that the full per-occurrence limit applies to whatever you shipped. It means the policy was written as a FAK policy rather than a single-commodity scheduled policy. The commodity description tells you the form. It doesn't tell you the sublimits.

FAK is standard for general freight carriers. One policy covers multiple commodity types — that's efficient and appropriate. The problem is that FAK policies almost always include commodity-specific sublimits and exclusions that live inside the policy, not on the certificate. The reason is actuarial. Electronics, pharmaceuticals, jewelry, tobacco, and alcohol are high-theft, high-value commodity classes that insurers price differently from paper towels or auto parts. If a carrier bought a $100,000 FAK policy at a standard premium, that premium was calculated based on the commodity mix they declared when they applied. If electronics were in that mix, they were separately rated. If they weren't, there's an exclusion or a sublimit that applies when a broker ships electronics anyway.

The certificate tells you the policy exists. It tells you the total per-occurrence limit. It tells you nothing about what happens when the loss is on the carrier's $500-per-unit laptop sublimit instead of their $100,000 general limit.

The Exclusions You Won't See

I've looked at enough cargo claims to say with confidence: the exclusions that surprise brokers are not in fields they'd think to check. They're in the policy language. Common ones:

Electronics and computers. The biggest one. A significant share of FAK policies either exclude electronic equipment outright or impose a per-unit sublimit — $500 per device, $1,500 per unit — that makes the per-occurrence limit functionally meaningless on a full trailer of tech. You don't find this on the certificate. You find it after the loss.

Pharmaceuticals. Frequently excluded or heavily sublimited. The theft risk is high, and temperature-related claims create ambiguity about whether the loss is cargo damage or product liability, so insurers get conservative.

Tobacco and alcohol. Both are high-theft commodity classes. The exclusions aren't universal but they're common enough that you need to verify before you assume coverage applies.

Jewelry, watches, and precious metals. Often a flat exclusion, sometimes a separate rider requiring advance notice to the insurer before hauling.

Theft while unattended. This one catches brokers on ordinary freight, not just high-value stuff. A lot of FAK policies have a "secured facility" condition: coverage applies to theft only when the trailer is parked in a locked, fenced facility when unattended. A truck parked overnight at a Flying J? Depending on policy language, that's potentially outside coverage. This isn't obscure fine print — it's a standard condition that applies in exactly the scenario where cargo theft most often happens.

The theft-unattended condition doesn't show up on the ACORD 25. The ACORD 25 shows that a cargo policy exists. What conditions must be met to trigger coverage — that's in a document you haven't asked for.

The Federal Floor Is Lower Than You Think

Under 49 CFR Part 387, there are federal minimum financial responsibility requirements for motor carriers. The liability minimum for a general freight carrier is $750,000 per occurrence — that's the MCS-90 endorsement or BMC-91 filing, the public-liability coverage that's actually federally mandated.

Cargo insurance is not federally mandated for general commodity carriers. At all.

Under § 387.301, FMCSA sets the public-liability requirements. Cargo insurance requirements under § 387.303 apply to household goods carriers and certain other operations. A dry van carrier hauling general freight? The federal floor on cargo coverage is zero. No federal minimum. Not $50,000. Not $10,000. Zero.

The cargo insurance your carrier carries exists because your carrier agreement requires it. It's a market requirement, not a legal one. The carrier bought whatever policy met your minimum limit. What commodity classes are covered at what sublimits — that was entirely between them and their insurer. You set the minimum dollar amount. You never touched what the policy covers inside that amount.

This means: if you required $100,000 in cargo coverage, and the carrier bought $100,000 in FAK coverage with a $18,400 sublimit on electronics, they met your requirement exactly. Your carrier agreement didn't say "no sublimits." Nobody's did.

What to Actually Ask For

Asking for the ACORD 25 is the baseline. You need it. It confirms the policy exists, the per-occurrence limit, the effective and expiration dates, and the named insured. Those are necessary. They're not sufficient for any load with real value on it.

For a load with invoice value over $50,000, or any shipment in a high-theft commodity category — electronics, pharma, jewelry, tobacco, alcohol — you need one more step: ask whether there's an exclusion or sublimit for your specific commodity.

Two ways to do it. One: request a copy of the FAK schedule or commodity endorsement directly from the carrier. Some carriers will produce it, most won't without prompting, but it's a reasonable ask and the response tells you something either way. Two: call the insurer. The phone number is on the ACORD 25. Ask two questions. First: is there an exclusion or sublimit for [commodity type]? Second: does the policy have a secured-facility condition for theft claims?

The call takes five minutes. Write down the name of the person you spoke with, the date, what they confirmed.

If you can't get an answer, that's information. A carrier whose insurer won't confirm commodity coverage on a high-value load isn't a carrier you should book for that load. Find one whose coverage you can actually verify. The verification step exists precisely so you don't get 19 cents on the dollar after the trailer disappears.

One thing worth noting: for very high-value loads, it often makes sense to confirm that whoever holds the beneficial interest — the shipper or the consignee — has their own cargo insurance as a backstop. Shipper's interest coverage exists exactly for scenarios where the carrier's policy falls short. That's not a carrier vetting step, but it's worth raising with the shipper before a $200,000 load of electronics moves on a carrier's FAK policy you haven't fully read.

Post-Montgomery Exposure on a Coverage Gap

Before May 2026, a broker who missed a cargo coverage exclusion faced a business dispute and a damaged customer relationship. After Montgomery v. Caribe Transport II, LLC — the unanimous Supreme Court decision holding that the FAAAA doesn't preempt state-law negligent-selection claims — the analysis is different.

The question plaintiff's counsel will ask isn't just whether you verified that the carrier had cargo insurance. It's whether you took reasonable steps to verify that the insurance was actually adequate for this specific load. Did you know the commodity was high-theft? Did you ask about commodity-specific sublimits? Did you document that inquiry? Or did you look at the ACORD 25, see "$100,000, Any Commodity," and stop?

"I saw the certificate" isn't reasonable care when you're booking $97,000 of laptops on a cross-country run. Reasonable care includes knowing what the certificate doesn't tell you — and asking one question to fill that gap.

The broker in my story didn't do anything reckless. She did what most brokers do. That's the problem. The standard is moving. The documentation that used to be adequate isn't always adequate now.

How I Document This

For any load over $50,000 in commodity value, or any shipment in a high-theft category, my carrier file includes:

1. ACORD 25 with cargo coverage verified against FMCSA L&I system (not just the certificate — L&I shows the actual filed coverage and effective date).

2. A record of my inquiry to either the insurer or the carrier confirming no commodity exclusion or sublimit applies. Email is better than phone — it creates a written record. If I called, I note the date, time, name of the person I reached, and what they confirmed.

3. Commodity description on the bill of lading and rate confirmation, cross-referenced to the coverage I verified.

4. If the policy has a theft-unattended condition: a note confirming the route is same-day or the carrier has confirmed a secured overnight facility.

That's the file. Not the ACORD 25 alone. The ACORD 25 plus the one question that the ACORD 25 doesn't answer.

The broker who got $18,400 back on a $97,000 loss verified that the policy existed. She didn't verify what the policy covered. One email would have changed what happened next. Not because it would have changed the theft — but because it would have changed who was left holding the loss.

— Mason Lavallet

Founder, DOTScreener.com