TIA President Chris Burroughs & Trinity CFO Doug Potvin Discuss the FMCSA Transparency Issue | Episode 45

Hey, everybody. It's Patrick Escolas with another Banyan Technology podcast, Tire Track. I'm here with Chris Burroughs, the President and CEO of TIA and Doug Potvin, the CFO of Trinity Logistics. Now, the CFO, it stands for Chief Fun Officer, I know. And TIA, you got to tell me what that is, other than referring to my aunt in Spanish. So, whoever wants to go first to address those very important intro points, go ahead.

No, I appreciate that. You remember very well, Patrick, that's what I introduced myself as a Chief Fun Officer and the Chief Financial Officer at Trinity Logistics. Been here 18.5 years, seeing this industry change over the years. Part of what we're talking about today, more changes.

Chris, give us your intro, sir.

Absolutely. Chris Burroughs as Patrick said, President and CEO of TIA. Assumed this role at the end of November, but certainly not new to TIA in the industry. I've been with the organization about 13 years at this point. Prior to serving as President and CEO, served as Vice President of Government Affairs. So, so obviously, I know quite a bit and kind of been in the trenches on this issue and several issues dealing with regulations and legislation over the years. So, looking forward to the conversation.

That's a perfect transition right there. Now, normally, I'd go into a bit about your organizations and companies, but I know today, we're talking specifically about some legislature that is either being pushed through or what the – I'm not sure exactly what status is at, but I know it's something that's supposed to – it's at least labeled about transparency in the broker area. Please, Chris, you said you've got the government background. Give us a little understanding of what this is and where it is. Then, we'll talk a little bit about what those consequences could be, and different takes on what should be done about it.

To kind of paint the picture here, set the stage a little bit. The regulation that's in question here, it's CFR, the Code of Federal Regulations 371.3. So, that's the number that gets thrown around a lot, so people would know what we're talking about. Essentially, it's dealing with brokered transparency, if you will, in terms of parties to a brokered load have access to certain information, including financial information. This particular regulation dates back to May of 1980, when the industry was drastically different. At that point in time, freight brokers were a commissioned sales agent of trucking. Meaning that, brokers went out on behalf of the trucking companies, they found freight from them, from shippers. Based on that relationship, they were paid a commission by the trucking company for finding them loads.

Okay. So, 1980, and now, we're in a little thing called 2025, freshly, why is this being brought up again? Has this always been on the books or what's happening to make this relevant?

Yes. So, it's always been on the books. Like I said, it's been around since the eighties, or 1980 particular. But whenever there's been a major downturn in the economy, back in 2008 with the housing bubble, few years later than that, with 2016, 2017, there was a downturn in the economy. And obviously, most recently, with the 2020 COVID pandemic, there's a major downturn in the economy. Questions are raised about supply and demand, and supply chain, and freight prices.

This argument tends to pop up that, "Hey, these brokers are taking too much off the top. They're screwing us over. They're taking advantage of the current economic situation." None of which is true, but this argument does pop up. So, this happened in 2020, there was all those trucks that were out protesting on the National Mall here in Washington, DC.

Sure.

Everybody remembers that.

Yes.

President Trump at the time, first term, sent out his chief of staff, Mark Meadows, talked with the carriers. There was a lot of back and forth on this. What happened because of those protests is, two organizations filed a petition for rulemaking, which means that they're asking this case, the Federal Motor Carrier Safety Administration to, "Hey, this is what we want to see it happen. We want to propose rulemaking on broker transparency." Particularly what they asked for was, which is now where we are kind of fast forwarding to now, today's environment, is a notice of proposal making. They're asking basically to take the 1980s regulation and enhance it, kind of bring it into a modern time in terms of how the information is disseminated, what type of information should be disseminated, making differentiation between what is a broker activity, what is it, what is a non-business broker activity.

They went as far to ask in their petition that the FMCSA step in into private contract negotiations. That part wasn't included, at least in the proposed rule. But again, this is a proposed rule at this point. The comment period closes on the 21st of this month. Last check, there's about 2,500 comments, currently sitting in a docket. They'll take all these comments, they'll read them all, and then they'll come out with, if it goes to the way that the normal process is, a regular order, if you will, it will take a period of time between the common period closing and issuing a final rule. Then, they just see what comes out of the final rule and say, "Hey, this is what we're going to do, or what we're not going to do. We may keep the status quo. We may make further changes based on the comments we received," et cetera.

So, it's really taking us back, in our opinion, back to a little bit of regulation, our regulatory environment in the trucking space and brokerage space, really what – coming off the 1980s when this was put in place, it was coming off a trucking deregulation. There's a very competitive marketplace out there.

Thank you for kind of setting the ground here. Lord knows I wouldn't have been able to go into that kind of detail without just hitting the high points there. But within that, and I want to hear from Doug in a second here, but what – and you said, it's the economic down that makes this come back up. But, since 1980, have more enhancements been brought up to this point, or this is the first time enhancements are being added to it, and it's been threatened before? Then, second part to this, why brokerage out of all of the different economic or industry placeholders that are going to affect the overall downturn of the economics, or inflation as a whole with people looking at it. Why is it a target or are things like this happening to different industries as well?

Yes. First question is, there has not been any enhancements to this point. This is kind of the furthest this argument has gotten to this proposed rule point. Secondly, I think the only one that we have seen recently would maybe be the airlines in terms of some of their transparency fees. Obviously, a different scenario when you're talking about a B2C versus a B2B market. But I think it's worth, and I don't want to take too much time, so Doug can jump in. But I think it's worth looking back at why, at the time, the Interstate Commerce Commission in the 1980, which doesn't exist anymore, it was a sunset, put this in place, is they were very concerned. Again, there's that commission model between the trucking company and the broker. They were concerned about this issue called freight rebate, where potentially, a shipper and a broker could be common owners. They didn't want to create a scenario where essentially, a shipper could be double dipping, and getting, paying – essentially, the loads are getting siphoned off to the broker, who's the same owner, who's then getting paid by the carrier for these loads. You see, it was called free rebating.

It was kind of like money – it was almost like money laundering at that point, right?

Essentially, yes. But that's what they were concerned about. I mean, they have in their notice, we don't – we're not regulating what the commission is. It's a very open, competitive marketplace. We don't want this regulation. Again, we're talking about 1980. We don't want this regulation to deterring through a competition in the space. You don't have to use a broker. If you choose to use a broker to source your loads, hey, there will be these parameters in place to go, and look, and see what the commission could be from the shipper.

Again, the marketplace couldn't drastically be any different now. Carriers don't pay brokers any sort of commission for sourcing loads. I think, it's probably a good stage to set up Doug there to kind of take it from here.

Yes. Doug, let's get your perspective. Also, with that, I would assume that transparency in of itself isn't necessarily negative, but what they're asking got to be a little more drastic than just saying, "Hey, I'll open my windows every now and then." This sounds like, "Hey, I want the blueprints. I want your IP address, and all of your passwords, and social security numbers." But go ahead, Doug.

Yes. I was going to say, this is an interesting dilemma for the capitalism society. You get two different transactions going on in this. You have our shipper customers who we negotiate a price to arrange transportation from movement from point A to point B. That's a completely separate negotiation, separate deal. We're taking a risk on whether that customer pays us or not. We've got the insurance backing. So, we're there from that standpoint. And in turn, we then offer that freight arrangement out to the motor carrier to actually provide the transportation services. And the carriers have the right to choose to take the load or not take the load in that nature, based on their costs and what they need to do, and we negotiate that. It's not that the price is dictated or anything of that nature, it's simply negotiations.

There are many carriers who come in and say, they need this rate. Unfortunately, we can't honor that rate, and so, we negotiate it. Sometimes, in the end, I believe it's a happy medium that is done between both parties, between the shippers and customers. That's one side of just a capitalistic idea that they're two separate transactions. Providing the information per se, I don't know what it does, and that there's a lot of cost that the broker takes in place, insurance, technology. These are opportunities for smaller carriers to get opportunities for loads they may not get, or they're going to hire a sales force. They got to hire this, that, and the other to be able to penetrate these shippers. This allows these carriers to haul for some brand-name

customers.

It's a give and take, and has been over the years. The interesting thing about this is that, I've been here 18.5 years, and not a lot of requests have come under these regulations for information from us. I think that's probably true in the industry.

You bring up a really good point. No one is under coercion here. Somebody needs to move something, and they could go directly to a carrier if they needed, but they're choosing to go to a broker with those value ads. And the same with the carriers, they could go directly out and try to find shippers, but they're trying to get the value ad of a full sales force that the brokerage offers. That seems to me like both sides would be coming to the table openly and not being at gunpoint. With something like this, looking at more of an enhancement here, and with looking in for more, Chris, what does it exactly entail? What do they want? Is this like, "Hey, I want to know what the raw cost is on every load"? What are we talking about here from a spot of transparency? Do you just want to know, "Hey, I made money on this"? Or, what level of detail is being looked for?

What the proposed rule calls for is, within 48 hours of delivery, they want the broker to electronically submit how much money basically they made from the shipper. They

Want the margin information. We've asked these groups. Hey, what are you trying to gain from this information?

What do you do with that?

Yes. Are you looking to back solicit? What's the end goal here? Their common response is, "Hey, we want to know who the bad players are in the space. We want to figure out who's screwing over the little guys."

But again, we've talked about this. It's not necessarily – no one is forcing anyone to move here. So, to even call it a bad player is strange to me. Because sure, someone crazy enough might make a giant margin on it, but obviously, a lot of things fell in

place for that to happen. Because usually, if something's really high, you're going to go, "Okay, I'm going to look at four or five other options." I doubt there's a lot of places in this country where you only have one way to move something.

Obviously, we're talking about the spot market here. Let's talk about transparency. There's a ton of transparency already in the marketplace through DAT or truckstop.com. Maybe they're just called Truckstop now. But Truckstop, in terms of go on the load boards, and you can figure out what are the lanes, their particular lane that you maybe want to operate in, get a pricing for that. And you can pretty quickly tell if somebody's giving you a fair rate or if somebody's trying to give you the shakedown.

Is the push for enhancement coming more from someone thinks someone's getting screwed on the shipper side or is this wrapped up in a bow and saying, "I'm protecting carriers?" Where's the push, where's the justification, and who's the victim here right now?

Of course, it's really coming from the small carrier groups. Those are the folks that asked for this, that petitioned the agency. Those are the folks that are making a lot of noise about this.

Again, if, of course, this happens for whatever reason and they can see that, what is that small carrier going to do any differently? Are they then going to be able to know what price to hire? I find it difficult that this helps them in any true way because it's just getting the information out there. It's not saying, "Hey, you can't do something," or, "Is this a step one in some other larger scheme?" Not scheme, I guess, but a thought process for either regulation, compliance. I don't see what the end picture is that would help anyone right now.

Right. We started with the same thing. I'm sure Doug does as well. We see this ultimately, this is obviously hurting the shipper in terms of proprietary information getting out there, kind of their competitive advance marketplace. Two, it obviously, it hurts our members in terms of being that conduit and protection of that information, kind of the value add that we add to the marketplace. Again, potentially being undercut, back solicited, undersold by the carriers.

Again, to Doug's point in terms of the sales force, this is going to hurt the small carriers more than the large carriers who have sales forces to go work with these brand name companies to source freight. Ultimately, when you're talking about increased regulation, I don't care what it is across the board, it adds cost to everything. If it's going to bear the cost of that at the end of the day, it's going to be the consumer. So, it's going to be the three of us when we're going to the grocery store, or a Target, or wherever the case may be, and picking out a certain product. Any sort of added regulations got to add cost at the end of the game.

Going back to that comment about bad players, Doug, there's got to be a lot of compliancy and regulations in place to prevent that as it is. What is Trinity or a broker like your size already have to deal with to stop these bad players as they were anyways?

It's interesting. So, the portion from us technology and over the last couple of years, the industry has been fighting freight fraud. Carriers coming in there to the tunes of millions, if not millions of dollars. I mean, for Trinity itself, it's in the seven-finger cost that we've had. So, it's employing this technology to make sure that the shippers' goods are entrusted with reliable carriers. That's what we try to do. So, we've got additional costs as a broker to make sure we're providing reliable carriers to these shippers, which is an important part of this.

I mean, one thing Chris alluded to is that, we've got contracts with our customers, indicate that we've got to keep information confidential. A lot of this has to do with the pricing on lanes. Their cost of what it costs them to move product from A to B. If that information gets out and continues to be getting out, we have all of a sudden damaged our shipper customer in information. That creates issues. I'm not sure if many shippers realize about this transparency rule now. Patrick, you guys have some shipper customers for the Banyan product.

We do, we have one or two.

I think they also need to understand, this is actually going to impact them as well. This information is going to have to be disclosed and how it gets out on that nature, portion of it. Going back to original question of compliance, to make sure we're compliant with the customer contracts associated with it. Compliance with the people, the carriers that we're actually using in this process and providing that vetting process for these shippers on that nature.

Here's something that I don't know the answer off the top of my head. Is, are there other industries where you are regulated and are forced to explain your exact amount of profit? I guess, here's a better question. Is this information going to go out to the public or is it going to go out to some small agency? Is this something that I should expect to see at the grocery store when I go to buy cereal. It's going to say, "Hey, here's the cost of production. Here's the cost here, and here's our margin." I can pick based on cheapest cost or lowest margin. Where else would this even apply? Is it just because the interstate is in place that this has any grounds to be pushed?

The only industry that comes to my head are utilities. The utilities are monopolies to begin with. This particular industry, you get over 800,000 carriers you're able to choose from and select from to move. You've got over 8,000 brokers registered doing this business, and then you got the host of number of shippers. I mean, we clear leads, 500 customers a day keep coming into us of potential customers. So, there's such a capitalistic society here, and they're asking to share this information, and in the end it's disrupting, it goes back to Chris' point, all it does is disrupt, and will cause increased costs in the entire supply chain, which I will argue during the pandemic, and I know I stated this before, is that it was because of the brokers and the small carriers that the supply chain did not break during the pandemic.

They did a tremendous job and we value – Trinity here values our carriers as much as we do our shippers. There's no doubt. Because without both of them, we are not successful in what we do.

Yes, you're mediator between us and otherwise. And Chris, you've been dealing with the government and you're a more the advocacy for the brokers for good reason. What do you have to say about when I you know say, I don't go to the grocery store and see margin. Why, again, is it specifically to this industry? Because a lot of people were showing a lot of companies and industries, or thought to have made profit coming out of COVID to be there at this place of inflation, you hear about it all the time. Why is this not? It doesn’t sounds like this is happening across the board. It sounds like it's happening only in one place.

I would say the other analogy that kind of gets brought up a lot is real estate agents. But again, we're talking, that's a perfect analogy when you're talking about the 1980 Interstate Commerce Commission model. So, when we're talking a commission based, sure, but I think this regulation makes sense and that's where you can bring in the analogy of a real estate agent. They're pretty clear and transparent what their commission is, but again, we're not dealing with May 12, 1980 regulation from the Interstate Commerce Commission where we're paid commission from the trucking company. That model is gone and has been gone for a number of years, quite frankly, not too long after this was put into place.

We're certainly an advocate of, let's modernize the industry, let's get rid of this burdensome regulation that continues to rear us ugly head during a downturn in economic times. Contrary to belief, we are a pro-carrier group. To Doug's point, we cannot exist without trucking companies.

Yes, just don't listen to us because in transportation, we're always complaining. Don't take it personally. We have nothing else to talk about.

A lot of those being the small interpreters. I have a very good working relationship with the folks over at OOIDA. I think they do great work. And 95 % of the issues we agree on with them, this one we don't. But I'm looking at a letter here recently that Todd Spencer, the president and CEO of OODIA put out to the Commerce Committee talking about the nomination hearing for Sean Duffy tomorrow for Department of Transportation, the hearing is happening tomorrow. He says, “We believe Duffy would guide the department in reviewing overreaching regulations that do nothing to improve safety and make it more difficult for small business truckers to survive.”

I couldn't agree more. I think brokerage transparency is a perfect example of an overreaching regulation that does nothing to improve safety. Doug talked about the issue of fraud. There's another great example. At one point in time in 2020, we asked the FMCSA, how many complaints are near National Consumer Complaint Database addressing fraud? They said 80,000 complaints. He said, “How many are dealing with broker transparency?” They said, “Maybe five.”

Yes, that seems so –

The agency is doing nothing. They're talking about modernizing the registration system. We'll wait and see if that happens. They're doing nothing to address this issue for all this costing the industry billions of dollars. It's killing carriers. It's killing brokers. It's killing shippers. Talk about consumers and inflationary market. But we're worried about transparency and we're worried about contract, private contract negotiations between shippers, brokers, and then brokers and carriers. I mean, it's a complete overreach by the current administration.

You bring up a great point there. So, with this, obviously you're against it. What could this do for the future? Say it does go through, no one puts up their hands and it's all goes, what are we going to see? What are the changes here? And what drastically is going to happen if everybody does nothing and they're able to put this enhancement in?

Yes, I was going to say, I think what you're going to see is you're going to see supply chain disruption. You're going to see cost increases that Chris alluded to, right? You're going to have a slowdown of this. You're going to have carriers say, “Hey, this guy's bad. This guy's bad.” When in actuality, it's probably not in that case. All of a sudden, you create this disruption within supply chain and we know what happened in disruption is probably due to COVID, right? You see all the prices increase to see store shelves empty. If disrupting the supply chain, well, in the attack the delivery of goods across this country. And does that look like the worst-case scenario? I'm not saying it's the worst case. It is a scenario that could happen. It all depends what happens with that information.

Then, do shippers all of a sudden say, “Hey, we're just going to use large carriers because we know our information is going to stay right there. We're not going to use the spot market. We're not going to deliver stuff out to a broker now for this stuff.” So, now you're talking really a shrinking of the – you can see consolidation in the carrier industry, dramatically there. You got –

And there’s –

– where you got that issue going on that maybe these people can't even lease on anyway, they become employees of the carriage. There's a whole list of things that could potentially happen that I'm not saying are worst-case scenarios. They're actual scenarios that could occur.

Yes, and that makes sense to me. That sounds like something that would happen if all of a sudden people are deciding that they're just not working with someone because they're making money off of it. More importantly, don't we expect people to be able to make money on this? Or else, what's the point of someone putting a carrier and a shipper together? Why wouldn't you just get out of the way? Why wouldn't you get out of the way and let a carrier do whatever they need to do and have a shipper pick up the phone as many times as they need to?

I mean, again, like I said, and this is even trying to take a neutral stance. I get the idea that you want transparency but just having transparency within 48 hours to get that out, it seems like just adding a nuisance to just any business process, even on top of giving that information out with it. It's hard to see what the true gain is there from my perspective. Maybe Chris, do you see anything else that could happen from the future here in addition to what Doug said, and where else would the industry change or have a shift?

I think Doug really highlighted a lot of the key things that we're certainly thinking about. What's the end result going to happen with this information is obviously a major concern. The doomsday scenario is obviously, as Doug described, his shippers just decide, “Hey, we're not going to work with brokers anymore. We're going to work directly with the large trucking companies.” That obviously hurts everybody in the supply chain. That hurts the owner-operators.

But then the large and you can do whatever they want as far as their margin. I mean, is there something that says the carrier has to show their margin to somebody within 48 hours? Then that doesn't seem right.

Yes, great.

Because yes, like Doug said, you already have a lot of barriers to the industry to be a carrier, you got to get a truck that's within the current regulations. You have to follow all the compliance and regulatory, and maintain and compete with everybody out there, and then you're making it that much harder to get in, let alone make a living, which if I've found since I've been in this industry, that this is one of the true industries that you can really kind of make your own fortune. You can really decide how much work you're going to put in and see what you're going to get out of it. This seems like a direct kick in the knees to that kind of that almost the quintessential American dream there.

So, all right, we don't like this. We don't think it's a good idea. We don't think it makes sense and we're not even sure what it's supposed to solve. What are we doing? What are you telling people to do to get this off the book? A, to stop the enhancement, and I assume B, get the overall the order off of the paper, off the code off the regulation entirely so it can't come up, 6, 12 months from now when something else happens.

We see in the immediate nature, like I mentioned, the comment period closes January 21^st. So, obviously, we're recommending that all of our members go out, or 2,000-member companies go out and file a comment directly with the docket. Have your voice heard, express your concerns with this proposed rulemaking. Like I mentioned, in the beginning, there's about 2,500 comments already in the system, which is probably the most I've ever seen put into a docket. So obviously, it's an issue that a lot of people are passionate about. So, go out, make a comment, get involved with the grassroots advocacy. We're having those discussions with legislators now about how can we address this potentially moving forward.

Because again, I've been with the association 13 years. This is kind of the third big time we've dealt with this. This is the furthest along. It's like I mentioned, it's gotten to this point. We've got to address this. We've got to continue to work and find, win-win-win business relationships for not only us, but for the carriers as well. We can work together like we do in a lot of issues for the betterment of both of our industries.

Quickly here, who can make comments on this docket? Is it open to the public, anyone that may be in the industry, or it could be anyone off the street? Because, A, I'm thinking, well, you don't want Joe Blow off the street to make a comment. But at the same time, Joe Blow probably gets delivered goods. A shipper may need to comment because this is going to inherently affect them one way or the other. This isn't like we're just calling out to brokers to do something. Who are we calling out to if you have to? Is it anyone in everyone or is particular people?

Yes. I mean, the short answer is anyone can file a comment. It's a public docket. Several hundred of the comments that are in there are from an anonymous. There's no requirement on who can submit a docket. They don't weigh particular comments more than others. They may look at a trader organization like TIA will obviously be falling comments before the deadline. They may look at that and go, “Hey, this is a group that represents 2,000 companies.” They may look at Hawaii and go, “I don't know how that process works. I’ve never been at DOT.” But I know they review every comment that is submitted. They're required to read them. So, we recommend folks get activated and go in and file a comment.

And is there a website for that? How does somebody do that?

Yes, there's a website, there's a, like the federal government, everything's not easy. Let's go to regulations.gov. There's a docket number. You punch it there. It'll take you directly there. You hit the submit a public comment. On our website, we have a link to a voter voice campaigns, a grassroots campaign. We’ve got talking points. We have a brief on the issue. Go in and then hit, put in your comment, hit submit, sends a right to it.

Yes, like you said, nothing is smoother and more streamlined than a federal government process. With that, and, I'm going to kind of bring it back real quick, something that popped up in my head is you talked about all of the freight fraud cases and how somehow this is the one taking the spotlight, after something like this gets pushed aside is, one way or the other, is anything being done on that fraud aspect? Or are they even talking about it, or is it too big to do anything? This was easy for them to write something up and push it through. Why would something like this get more of a green light than something that seems industry-wide and a big problem? Do you have any insight to that?

Yes, that's really kind of our big question, is why are we shining a spotlight on this private, really negotiations between parties versus an issue like freight fraud? They're talking about working on a modernization registration system, like I mentioned, where they're going to have personal background checks, business background checks to see that the folks that are coming in are legitimate. Here at TIA, we're working on legislation with OOIDA and other industry groups in collaboration to require the agency to enforce some of the regulations that are already on the books.

One, for instance, being the principal place of business requirement. You have to have your principal place of business being where you're actually physically doing business. The agency does not enforce this. Send me emails saying that. There's about 9,000 trucking companies that use a P.O. Box or FedEx box today that are not adhering to this regulation.

That'd be an easy one to track down too.

So, there's so much fraud going on. It's such a massive issue. We're having numerous conversations with media about it. It's a huge problem.

Yes. So, it'd be nice to redirect that. I think, you know, without beating a dead horse, I think, I understand what should be done here, but let's get kind of some closing statements to anyone that might have just jumped in at the end. But I'll start with Doug here. On this topic and kind of as a message from you to anyone listening in general, what do you got, Doug?

Yes, just in closing thoughts, it's really a capitalistic market that we're dealing with in the middleman, and between the customer and the carrier in that nature of shipper customer. I know that your podcast reaches shipper’s customers because I know that's from a Banyan perspective. And I would ask that they should go in there and provide their comments, or do they want their information potentially being spread throughout, beyond just this, right? Because we don't know whether that fraudster carrier may be picking up load and all of a sudden, we're sending information to him and he gets it out.

I mean, it's things of that nature just to realize it's capitalistic. We do a great job, our carriers do a great job for us. It's been a win-win for the last 18 and a half years for us and the carriers that we've utilized.

Thanks Doug. I think you summed that up really well there. I'm just going to give Chris a chance here since he's in the trenches as he calls it. This is what TIA is around for. Chris, what have you got as a closing statement here as the president and CEO of TIA against this regulation?

Yes, I would just say, get involved with the process, take action, file your comment. If you're for this or against it, it's better than everybody to get out there and have their voice heard. Obviously, we as an association are opposed to it. The agency kind of to your point, let's redirect the resources to issues that matter, like freight fraud, that's a huge issue. Let's work on addressing the truck parking shortage that's going on throughout this country. There is no safe, reliable truck parking for carriers. That's a massive problem. Let's deal with the nuclear verdicts that are going on in the space that are crippling the industry in terms of insurance cost. These are issues that are impacting everybody across the board. We want to be a partner for carriers. We're not the enemy. We're here. We cannot exist without you and appreciate all the great work that our members and the truckers are doing out there.

Hey, that's a great message. I'll just follow up for anybody listening here. One way or another, get your voice out. Get a comment on there. Time is running out, but this is important and it doesn't sound like it's a good use of resources. It doesn't sound like it's in the right mindset and there's probably something better to be done. But don't listen to me, listen to the people like Chris and Doug, and they know what they're talking about a lot more, and they don't think this is a good idea. So, take a minute, put your comments out there, and see if you can make a difference here.

Guys, thank you very much. I really appreciate your insight here. I'll be listening to see where this goes. I know I got to go make a comment now and find out on a federal website if I can actually navigate it. But I'll do it. Yes, appreciate your time, Chris. Keep fighting the fight. I know that as it said, the combat starts soon. Doug, keep bringing fun into an otherwise boring accounting office. Come on, man. Thanks guys. I really appreciate your time today.

Thank you, Patrick.

For everybody else, this has been another episode of Banyan's Tire Track Podcast. I'm Patrick Escolas and I wouldn't be anywhere else. Thanks guys.