The $750K Floor Isn't a Safety Net — It's the Minimum Wage of Truck Insurance

A broker I know — won't use his name — tendered a flatbed load to a carrier out of Joliet in late 2023. Carrier had an active MC, decent history, and a certificate of insurance showing $750,000 in BIPD coverage. The load was an industrial conveyor system worth about $115,000. Everything looked standard.

Six months later, one of their drivers blew through a rural intersection in Mississippi. Side-collision with an SUV. The driver of the SUV survived but spent four months in in-patient rehab. One passenger — the driver's daughter, twelve years old — didn't make it. The estate filed. The jury came back at $2.3 million.

The carrier had exactly $750,000 in coverage. They were a three-truck operation. Their trucks were their only assets. The plaintiff's lawyer sent a subpoena to the broker.

This isn't rare. It's one of the most common ways a broker ends up in litigation they didn't see coming — and the root of it is that $750,000 number on the COI looked like coverage when it was actually a floor.

Where That Number Comes From

49 CFR § 387.9 sets the minimum financial responsibility for motor carriers of property. For general commodity freight — your standard dry van, flatbed, or box truck — the minimum is $750,000 in BIPD. That's bodily injury and property damage. Carriers moving petroleum products have a $1 million floor. Carriers moving hazardous substances listed in the DOT hazmat table have a $5 million floor.

The $750,000 number for general freight comes from the Motor Carrier Act of 1980. That's not a typo. 1980. The number was set when a new semi cost around $40,000, hospital stays were a fraction of current billing rates, and wrongful death settlements in rural counties were often under six figures. In 46 years, the regulatory minimum has not moved once.

I'm not saying that to be dramatic. I'm saying it because the number on your COI has no relationship to the actual exposure you're looking at in 2026. The minimum is the minimum. It's not a signal that the carrier is adequately covered. It's the legal floor for operating authority, and plenty of carriers sit right at it.

What the COI Doesn't Show You

The ACORD 25 certificate shows the policy limit. It does not show you the deductible. It does not show sub-limits. It does not show exclusions, and it doesn't tell you whether the policy has been canceled and reinstated.

Deductibles matter more than most brokers realize. A carrier can show $750K in BIPD with a $75,000 deductible baked in — meaning the first $75K of any claim comes out of their pocket. A small carrier without working capital may not have $75,000 liquid. When the claim arrives, the carrier disputes, delays, or simply can't fund the deductible. The insurer may refuse to engage until the deductible is satisfied. Claims drag. The broker sits in the middle.

Then there's cargo. BIPD covers the other people — the folks in the SUV you hit. Cargo coverage is a completely separate policy that covers your shipper's freight. A carrier showing $750K BIPD and $100K cargo is fine for most standard freight — but if you're moving $250,000 of medical equipment, your shipper is $150,000 short on coverage before anything else goes wrong. Those are separate discussions, and a lot of brokers treat them as one.

I've watched brokers pull a COI, confirm the $750K number, file it, and never ask what the cargo limit is relative to the declared shipment value. That oversight is real. It's also exactly the kind of thing that surfaces in discovery when the shipper's attorney starts building the paper chain.

The Coverage Gap Becomes Your Problem

Post-Montgomery v. Caribe Transport II, negligent carrier selection is a live issue in state courts across the country. The Supreme Court's unanimous ruling in May 2026 reversed the FAAAA preemption defense that brokers had relied on in the 7th and 11th Circuits. Negligent-selection claims can now proceed in state court.

That doesn't mean you're automatically liable if a carrier you booked has a bad day. But it does mean the question — "what steps did you take to select a safe carrier?" — is going to be asked under oath if something goes wrong. And part of "safe" is whether you matched the insurance picture to the load.

Handing a $180,000 shipment to a carrier with $100,000 in cargo coverage is a mismatch. Maybe the shipper accepted that risk. Maybe they have their own coverage that fills the gap. Maybe the broker got an additional insured endorsement. Any of those outcomes is defensible. Not noticing the gap at all is not.

On the BIPD side, the math is similar. A carrier sitting at the $750K minimum on a high-exposure lane — metro area, tight schedule, a load that requires permits — is coverage you need to think about, not just confirm.

A Scenario That Plays Out More Than It Should

MC-1389245, DOT-3102876 — a four-truck dry van operation out of Ohio. Active authority, 26 months old. OOS rate of 11.2% on vehicles. Two inspections in the last 12 months, one defect each. BIPD: $750,000 through a surplus-lines carrier. Cargo: $100,000 per occurrence.

A broker tenders them a load of commercial kitchen equipment. Two restaurant fit-outs worth a combined $212,000 in declared value. Destination: Las Vegas.

The cargo coverage is $112,000 short on declared value alone, before you get into the OOS rate or the surplus-lines insurer question. The broker confirmed $750K BIPD, confirmed active authority, filed the COI, and moved on. Nobody did the cargo comparison.

The load delivers fine. But then the same carrier, two months later, has a jackknife on I-40 outside of Albuquerque. No fatalities, but significant property damage and two injuries. The $750K is gone in hospital bills and property damage. The plaintiff looks at the carrier's assets and then looks at the brokerage.

This is when the file matters. What's in it. What wasn't checked. Whether anyone compared the cargo limits to any prior load values.

What I Actually Look At

The number I want on the BIPD side isn't $750K — it's what the exposure looks like on the lane. For a lot of standard freight on a regional lane, $750K is probably adequate. A carrier moving paper goods between two warehouses in the same state is a different conversation than a carrier moving refrigerated pharmaceuticals from New Jersey to Los Angeles through four high-traffic metro areas.

On cargo, I look at three things every time: the per-occurrence limit, the named insured, and the effective date.

Per-occurrence limit vs shipment value. I compare the cargo limit to the declared or estimated shipment value before I tender. If there's a gap, I note it and either require the carrier to get a rider, ask if the shipper has their own cargo coverage, or document that the shipper was informed and accepted the gap. Any of those outcomes is in the file. Not noticing is not.

Named insured. The certificate needs to match the operating entity. I've seen COIs where the named insured is a parent company, a leasing entity, or a d/b/a that doesn't appear on the FMCSA registration. That's worth a question. When a claim happens, coverage disputes often start with "the policy covered X, not Y, and the carrier running the load was Y."

Effective date and FMCSA filing. FMCSA's L&I database shows the insurance filing history for every carrier — every BMC-91X filed, every cancellation notice, every reinstatement. A carrier whose insurance has been filed and cancelled and refiled three times in the last 18 months is a different risk profile than one whose coverage has been continuous for the same period. The COI shows you the current certificate. The L&I history shows you the pattern. Both matter.

The Surplus-Lines Question

When a carrier's BIPD is written by a surplus-lines carrier, that's worth a second look. Surplus-lines insurers cover risks that standard admitted carriers won't underwrite — which often means the carrier's risk profile is elevated enough that the standard market wouldn't take them. That's not automatically disqualifying. But a surplus-lines policy in a state where the insurer has limited regulatory oversight is different from a policy written by a mainstream commercial trucking insurer.

49 CFR § 387.15 requires the insurer to file directly with FMCSA via BMC-91 or BMC-91X. The insurer on the FMCSA filing should match the insurer on the COI. When they don't — and it happens — there's a coverage question that doesn't resolve easily under a tight clock on a Friday afternoon.

The insurer quality point isn't about being picky. It's about knowing that when the time comes to write a $600,000 check, the carrier's insurer has the financial standing and the claims history to actually do it.

How I Document This

My insurance check for every carrier file includes:

• COI reviewed: BIPD limit and cargo limit noted with pull date
• Cargo limit compared to declared or estimated shipment value — noted explicitly
• FMCSA L&I database checked: insurance filing active, no recent cancellations or pattern of gaps
• Named insured confirmed to match carrier's FMCSA-registered operating entity
• Any gap addressed: method noted (shipper coverage, carrier rider, documented shipper acceptance)

That last line is the one that saves you. If I tendered a $180,000 load to a carrier with $100,000 in cargo coverage and the shipper knew, accepted it, and had their own policy as backstop — that's documented. If the shipper didn't know and I didn't check, that's not defensible. Same file, different outcome in discovery.

This isn't a long process. Comparing cargo limits to load values takes two minutes. Checking the L&I database takes about the same. The documentation is a note in the carrier file. None of this is complicated, and all of it matters if you're ever sitting across from a plaintiff's lawyer who wants to know exactly what you did before you handed that load off.

The $750K minimum tells you the carrier has enough coverage to operate legally. It doesn't tell you they have enough coverage for your load, your lane, or your worst-case scenario. That's your job to figure out.

---

— Mason Lavallet

Founder, DOTScreener.com