Hotshot Lease Agreements — Part 3: CA-Prong-B Template + Expected FMCSA NPRM (2026-08-12)

OG · · 19 min read
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Hotshot Lease Agreements — Part 3: CA-Prong-B Template + Expected FMCSA NPRM (2026-08-12)

Companion to:

TL;DR

  1. Worked dispatch-carrier agreement template — full clause-by-clause language for a dispatch services agreement (NOT a lease-on) that dodges California’s AB-5 prong-B trap. This is the structure the CA market has been pivoting to since the 9th Circuit’s May 2025 Bonta affirmation.

  2. Prediction of the FMCSA “Truth-in-Leasing Reform” NPRM (likely Q4 2026 / Q1 2027) — what FMCSA will and will not propose, given (a) TLTF + CFPB 2025 recommendations, (b) the Feb 11, 2025 CFPB “cease” order that kills the joint-agency framework, (c) Trump’s deregulatory posture.

1. Why the CA prong-B workaround matters

California’s AB-5 codifies the ABC test (Labor Code §2750.3). Prong B — work outside the hiring entity’s usual course of business — is fatal for a motor carrier that hauls freight for hire. The 9th Circuit affirmed AB-5 against trucking in California Trucking Association v. Bonta on May 22, 2025.

Three workarounds carriers have been using:

  1. Own-authority model. OO runs under their own MC. Carrier provides dispatch and factoring services only.
  2. §376.22 inter-carrier lease. Two authorized carriers lease equipment to each other.
  3. §376.21(c) equipment-only rental. Lease equipment (no driver) from a lessor principally in the rental business.

The dispatch-carrier agreement is the dominant pattern in 2024–2026 CA market. It is NOT a §376.12 lease — it’s a services agreement. The OO has their own MC authority and their own truck. The carrier dispatches; the OO bills the shipper under their own MC.

Why this dodges prong B: under the dispatch agreement, the carrier is providing dispatch services, not transportation. The carrier’s usual course of business becomes “providing dispatch and back-office services to independent owner-operators” — not “hauling freight.” The OO’s work (hauling under their own authority) is outside that. Source: TruckLeap, “Sample Dispatch-Carrier Agreement” (April 29, 2026); USA Trucker Choice, “Dispatch Service Agreement: What to Include” (Mar 8, 2026).

2. Worked Template — CA-Prong-B-Avoidance Dispatch-Carrier Agreement

Disclaimer: reconstructed reference structure, not legal advice. Have a California transportation attorney review before executing.

2.1 Document architecture — three separate contracts

Document Purpose Federal reg touch
(A) Dispatch Services Agreement between Owner-Operator (LLC, own authority) and Dispatch/Carrier Dispatch, back-office, factoring services. NOT a lease. None — §376 doesn’t apply because no equipment is being leased
(B) §376.22 Inter-Carrier Equipment Lease (if carrier provides trailer) Carrier leases trailer to OO under OO’s MC §376.22 (simplified docs)
(C) Independent Factoring Agreement between OO and factoring company Payment flow None

Critical separation principle: the OO is NEVER on the carrier’s MC authority.

2.2 Document (A) — Dispatch Services Agreement — clause-by-clause

Section 1: Parties and Recitals

“This Dispatch Services Agreement (‘Agreement’) is entered into as of [Date] between [Carrier Name LLC], a California limited liability company holding USDOT Number [number] and MC Number [number] (‘Carrier’), and [Owner-Operator LLC], a California limited liability company holding USDOT Number [number] and MC Number [number] under its own operating authority (‘Owner-Operator’).”

Both parties are distinctly-named LLCs with their own DOT/MC numbers. Owner-Operator holds its own operating authority (separate from Carrier’s MC). This single fact dodges AB-5 prong B if structured correctly.

Section 2: Definitions

“‘Dispatch Services’ means the services described in Section 3 of this Agreement, including load sourcing, rate negotiation, broker communication, rate confirmation delivery, BOL/POD processing, factoring, and back-office support. ‘Load’ means a single shipment of property from origin to destination. ‘Linehaul Rate’ means the freight charge for transportation exclusive of all accessorial charges, fuel surcharges, detention, layover, lumper reimbursements, and pass-through insurance charges. ‘Gross Revenue’ shall not include accessorial charges of any kind.”

“Linehaul Rate” is the basis for the dispatcher’s percentage fee. Accessorials pass through 100% to the OO. “Dispatch Services” is a closed list.

Section 3: Services Provided

“Carrier shall use commercially reasonable efforts to: (a) source freight loads from licensed brokers and shippers compatible with Owner-Operator’s equipment and operating preferences; (b) negotiate rates and terms on Owner-Operator’s behalf as Owner-Operator’s disclosed agent; (c) coordinate pickup and delivery scheduling; (d) submit required documentation to brokers including rate confirmations and proof of delivery; (e) provide rate confirmations to Owner-Operator prior to dispatch of each load; (f) process broker payments through Carrier’s factoring program (Section 7); (g) maintain records of all loads, settlements, and deductions for at least seven (7) years.”

Owner-Operator is principal in the broker-shipper relationship; Carrier is disclosed agent. This is critical for AB-5 prong A. “Commercially reasonable efforts” — no specific-load or specific-rate promises. Rate confirmations BEFORE dispatch.

Section 4: Compensation

“Owner-Operator shall pay Carrier a fee equal to [5-10] percent of the Linehaul Rate on each Load successfully delivered under this Agreement. Compensation shall be calculated on Linehaul Rate only and shall not include accessorial charges of any kind. Compensation shall be invoiced weekly and shall be due within fourteen (14) days of invoice. Compensation shall be net of any non-payment by broker, and Carrier shall pursue broker collection on Owner-Operator’s behalf at no additional charge.”

5–10% of linehaul only (industry standard per TruckLeap 2026). 14-day net. No weekly minimum. Carrier absorbs broker non-payment risk. No accessorial percentage.

Section 5: Owner-Operator Obligations

“Owner-Operator shall: (a) maintain active operating authority and required insurance coverage in Owner-Operator’s own name; (b) operate equipment in compliance with FMCSA regulations including HOS limits and CDL requirements; (c) freely accept or decline any Load offered by Carrier without penalty (Owner-Operator’s right of refusal is absolute); (d) deliver accepted Loads safely and on time; (e) submit BOLs and PODs to Carrier within 24 hours of delivery; (f) maintain commercial auto liability of not less than 1,000,000 per occurrence and cargo coverage of not less than 100,000 per shipment, in Owner-Operator’s own name.”

Owner-Operator may freely accept or decline any Load. No forced dispatch. No penalties for refusal. This is the most AB-5-defensive clause you can have — it makes prong A almost impossible to argue. Insurance in Owner-Operator’s own name.

Section 6: Independent Contractor Relationship

“Carrier and Owner-Operator are independent contractors. Nothing in this Agreement creates an employer-employee, agent-principal (except as expressly stated in Section 3(b) for disclosed agency), partnership, or joint venture relationship. Each party is responsible for its own taxes (including self-employment taxes for Owner-Operator), insurance, workers’ compensation, and compliance with all applicable federal, state, and local laws. Neither party has authority to bind the other except as expressly stated herein. Owner-Operator is free to haul Loads for any other broker, shipper, or carrier, and is free to obtain dispatch services from any other provider, at any time.”

Both parties are independent contractors of each other (symmetric). Owner-Operator can use multiple dispatchers. No exclusivity. Explicit tax allocation: Owner-Operator is self-employed.

Section 7: Factoring and Payment Flow

“Owner-Operator hereby authorizes Carrier to receive broker payments on Owner-Operator’s behalf through Carrier’s factoring program. Carrier shall remit Owner-Operator’s share of each Load payment (Linehaul Rate less Carrier’s fee under Section 4) within fourteen (14) days of Carrier’s receipt of payment from the broker. Carrier shall provide Owner-Operator with a written settlement statement for each Load showing: (a) gross Linehaul Rate; (b) any accessorial charges and confirm that 100% of accessorials were passed through; (c) Carrier’s fee calculation; (d) any deductions with itemization and supporting documentation; (e) net amount remitted.”

Owner-Operator authorizes factoring (not assigned — authorized). Settlement statement required for each Load. Itemization required for any deductions (§376.12(h) spirit even where federal law doesn’t apply).

Section 8: Insurance and Indemnity

“Owner-Operator shall maintain, in Owner-Operator’s own name, commercial auto liability insurance of not less than 1,000,000 per occurrence, cargo insurance of not less than 100,000 per shipment, and bobtail/non-trucking liability of not less than $1,000,000 combined single limit. Carrier shall maintain general liability and errors-and-omissions insurance covering its Dispatch Services. Each party shall name the other as additional insured on its respective policies. Owner-Operator indemnifies Carrier against any third-party claim arising from Owner-Operator’s operation of equipment. Carrier indemnifies Owner-Operator against any third-party claim arising from Carrier’s negligent provision of Dispatch Services.”

Symmetric insurance obligations. Mutual indemnification. No requirement to use carrier-affiliated insurance.

Section 9: Confidentiality and Non-Solicit

“Each party shall keep confidential the other party’s customer lists, rate information, and business methods. Upon termination of this Agreement, neither party shall solicit the other party’s direct-shipper customers for a period of twelve (12) months. This restriction does not apply to Owner-Operator’s direct-shipper relationships developed independently and disclosed to Carrier in writing prior to termination.”

Mutual non-solicit. Owner-Operator’s pre-existing direct-shipper relationships are protected even after termination.

Section 10: Term and Termination

“This Agreement shall continue for an initial term of one (1) year and shall renew for successive one-year terms unless either party gives written notice of non-renewal at least thirty (30) days before the end of the current term. Either party may terminate this Agreement for convenience upon thirty (30) days’ written notice. Either party may terminate immediately for material breach uncured after fifteen (15) days’ written notice. Upon termination: (a) Carrier shall remit all undisputed amounts owed to Owner-Operator within fourteen (14) days; (b) Owner-Operator shall pay all undisputed amounts owed to Carrier within fourteen (14) days; (c) each party shall return the other’s confidential information; (d) Owner-Operator’s right to use Carrier’s factoring program ceases and Owner-Operator shall arrange alternative factoring within 30 days.”

Either party can terminate for convenience. Material breach cure period of 15 days. 14-day settlement post-termination. Owner-Operator gets 30 days to find replacement factoring.

Section 11: Dispute Resolution

“Any dispute arising under this Agreement shall first be submitted to non-binding mediation in [County], California, before a mediator mutually selected by the parties. If mediation fails to resolve the dispute within thirty (30) days, either party may pursue binding arbitration administered by JAMS under its Comprehensive Arbitration Rules in [County], California. The arbitrator shall award the prevailing party its reasonable attorneys’ fees and costs. Notwithstanding the foregoing, either party may seek injunctive relief in any court of competent jurisdiction to prevent irreparable harm.”

Mediation first, arbitration second. Neutral venue. Prevailing party gets fees. Injunctive relief carve-out.

Section 12: Miscellaneous

“This Agreement constitutes the entire agreement between the parties. It may be amended only by a writing signed by both parties. If any provision is held unenforceable, the remaining provisions remain in effect. This Agreement is governed by California law. Notices shall be in writing and sent to the addresses set forth above by certified mail or by email with read receipt.”

Anti-OO provisions removed:

  • “This Agreement may be assigned by Carrier without Owner-Operator’s consent.”
  • “Carrier may modify this Agreement unilaterally upon 30 days’ notice.”

2.3 Document (B) — §376.22 Inter-Carrier Equipment Lease (trailer only)

If the carrier provides the trailer to the OO under OO’s own MC, it’s a §376.22 inter-carrier lease.

Required under §376.22(c):

  1. Signed by both parties (§376.22(c)(1)).
  2. “Control and responsibility for the operation of the equipment shall be that of the lessee [OO] from the time possession is taken by the lessee and the receipt required under §376.11(b) is given to the lessor [Carrier] until possession is returned.” (§376.22(c)(2) — verbatim language)
  3. A copy of the agreement must be carried in the equipment while it is in the possession of the lessee (§376.22(c)(3)).
  4. Equipment identification per §376.11(c) (make, model, VIN, license plate).

Exempt under §376.22: most of §376.12 (e) through (l) does not apply.

2.4 Why this works for prong B (and where it can still fail)

What makes it work:

  • Owner-Operator runs under their own MC authority. Freight moves under OO’s MC, not carrier’s.
  • Carrier’s role is providing services, not transportation.
  • No exclusivity.
  • No forced dispatch.
  • Separate insurance.

Where it can still fail:

  • If Owner-Operator hauls 100% of loads sourced by Carrier (courts apply “economic realities” test).
  • If Carrier dictates routes, timing, or rates.
  • If Owner-Operator doesn’t have multiple shipper customers (prong C failure).
  • If Carrier requires Owner-Operator to use Carrier-affiliated insurance, fuel cards, or factoring.
  • If Owner-Operator uses Carrier’s placards, branding, or signage.

Best practice: Owner-Operator should have at least 2-3 direct-shipper customers that Carrier doesn’t source, AND at least one alternative dispatcher they use occasionally.

3. The CFPB 2025 Report — What It Actually Said

Per TheTrucker.com, “FMCSA task force slams truck leasing practices” (Jan 23, 2025), the CFPB report (“Observations on Truck Lease-Purchase Agreements”) was prepared for DOT’s TLTF as a technical advisor report. Findings were based on contract text + driver RFI responses + industry research.

CFPB’s substantive findings:

  1. “There does appear to be use of inequitable leasing agreements and terms in the motor carrier industry, with noted differences between truck leases and auto financing that may create significant financial risks for drivers.” (Direct quote, Landline, Feb 11 2025.)
  2. Conflict of interest in debt + control: when the same entity holds the debt and controls the driver’s ability to earn and pay off the debt, the driver has no leverage.
  3. Driver testimony: RFI responses describing situations where drivers ended pay periods owing the carrier.
  4. Disclosure failures: vague language about deductions and settlement calculations.
  5. Lack of comparison shopping: drivers who can’t access traditional financing have nowhere else to turn.

CFPB framed lease-purchase as consumer credit, not employment — a different regulatory framework. Recommendations presumably included Regulation Z disclosures (12 CFR §1026) with TILA commercial-purpose exemption (§1026.3(a)) for trucks > 25K GVWR, FDCPA considerations, and state-level consumer protection enforcement.

3.1 What happened to the CFPB after the report

Critical update. On February 11, 2025 — one month after the CFPB report was published (Jan 17) — the Trump administration ordered the CFPB to “cease all supervision and examination activity.” Per Landline, Feb 11 2025: “The Consumer Financial Protection Bureau’s office is closed this week, and many of its services have been suspended following an order by the Trump administration. According to The Associated Press and several other media outlets, the agency was ordered to ‘cease all supervision and examination activity.’ As of Tuesday, Feb. 11, the home page of the bureau’s website included the message ‘404: Page not found.’ However, the website remained functional.”

The CFPB has not been formally abolished (Dodd-Frank is still in force), but it has been operationally gutted. Any enforcement actions under the CFPB report’s consumer-finance recommendations are functionally paused. This is why the CFPB’s full report is no longer being acted on by CFPB itself — which matters for the NPRM prediction in §4.

4. What the FMCSA “Truth-in-Leasing Reform” NPRM Will Probably Look Like

4.1 Current pipeline (as of August 2026)

FMCSA’s Federal Register document index is at fmcsa.dot.gov/regulations/federal-register-documents (Akamai-blocked from this host). I checked via regulations.gov and search engines.

As of August 2026, no Truth-in-Leasing Reform NPRM has been published. FMCSA has signaled in 2026 stakeholder meetings that an NPRM is being scoped, but no concrete docket ID or publication date has appeared.

4.2 What the NPRM will likely include

Given (a) Trump deregulatory posture, (b) gutted CFPB, (c) trucking industry lobbying against a full ban:

HIGH CONFIDENCE (very likely in any NPRM):

  1. Mandatory record-keeping by carriers offering lease-purchase. Carriers must report to FMCSA quarterly: number of LPAs entered, number of OOs who walk away with $0 equity, number who complete to title. (TLTF recommendation; administrative rule, low-cost, hard to oppose.)

  2. Whistleblower protection for drivers reporting predatory LPAs. (TLTF recommendation; moderate; may be punted to DOL.)

  3. Disclosure requirements on lease-purchase contracts. Carriers must disclose, in plain language: total cost to own at contract end, balloon payment amount, walk-away equity, early termination penalty, all deductions. (TLTF recommendation; mirrors CFPB framing.)

  4. 15-day minimum escrow accounting for any escrow held by carrier under §376.12(k). Current rule requires quarterly; NPRM may tighten to monthly.

  5. Mandatory written notice of OO’s right to a copy of the lease under §376.12(l). Many carriers “forget” to give the OO a copy. NPRM may require explicit acknowledgment of receipt.

MEDIUM CONFIDENCE (likely but could be trimmed):

  1. Insurance charge-back disclosure cap. §376.12(j) requires specification; NPRM may require mid-year change notice with 30 days’ warning before insurance charge-backs can be adjusted.

  2. Forced-dispatch disclosure. If a lease requires forced dispatch, the contract must state that explicitly and conspicuously. Likely watered down to just “must be in writing.”

  3. Settlement statement standardization. §376.12(f) requires payment in 15 days; NPRM may add a standardized settlement statement form (akin to a wage stub).

  4. Anti-coercion language in §376.12(i). Currently §376.12(i) says OO is not required to buy from the carrier. NPRM may add: OO cannot be charged for products/services offered by the carrier as a condition of continued operation.

LOWER CONFIDENCE (could be in or out):

  1. Insurance charge-back cap. Limit insurance charge-back to a fixed % of OO settlement (e.g., 15%). Heavily opposed by carriers; likely struck.

  2. Lease-purchase balloon cap. Limit balloon payment to some % of truck market value. Opposed by carrier finance arms.

  3. Walk-away equity floor. Require carriers to credit some portion of payments toward OO’s equity if they walk away. TLTF acknowledged this would be a “fundamental restructuring” of LPAs.

VERY LOW CONFIDENCE (effectively off the table in this admin):

  1. Outright ban on carrier-controlled LPAs. TLTF’s primary recommendation. Very unlikely under current administration.

  2. Multi-agency joint oversight (FMCSA + DOL + FTC + CFPB). CFPB is gutted; DOL IC rule rescinded March 2025. Not politically feasible until 2029+.

  3. Federal preemption of state ABC tests for trucking. OOIDA’s argument in Bonta — 9th Circuit rejected it. No NPRM will reverse that.

4.3 Realistic timeline

Quarter Likely event
Q4 2026 FMCSA publishes ANPRM (Advance Notice of Proposed Rulemaking) — “tell us what you think” request. Industry comment 60 days.
Q1 2027 FMCSA reviews ANPRM comments, drafts NPRM internally.
Q2 2027 NPRM published. Public comment 60–90 days.
Q3–Q4 2027 FMCSA reviews comments, prepares Final Rule.
Q1 2028 Final Rule effective (best case).

Realistic alternative: if the Trump administration decides to do nothing, no NPRM at all until January 2029+. Watch the Unified Agenda of Regulatory and Deregulatory Actions (April and October each year) for the official pipeline.

4.4 What the NPRM will NOT include (high confidence)

  • Outright LPA ban.
  • Federal preemption of state ABC tests.
  • Mandatory 30-day notice before any insurance charge-back change.
  • Mandatory walk-away equity floor.
  • Mandatory multi-agency joint oversight.

5. What this means for hotshot operators and carriers right now

5.1 If you’re a CA-based owner-operator:

  1. If you’re currently leased onto a carrier under a 49 CFR §376.12 lease — you have misclassification risk under AB-5. The 9th Circuit ruling applies to you. Consider asking the carrier about restructuring as a dispatch-carrier agreement under your own MC authority.
  2. If you’re running your own authority — the dispatch-carrier agreement structure in §2 is the CA-market-standard contract. Use it as a template, but get a CA transportation attorney to review before signing.
  3. Don’t sign a lease-purchase in CA unless you’ve had a third-party lawyer review it AND you have explicit walk-away equity AND the balloon is reasonable vs. market value.

5.2 If you’re a carrier:

  1. Audit your CA-resident OOs immediately. If you have OOs in CA running under your MC authority via §376.12 leases, you have material misclassification exposure.
  2. Restructure as dispatch-carrier agreements for CA OOs.
  3. Don’t structure LPAs to maximize walk-away leverage — even without a federal NPRM, you have (a) the CFPB report’s findings on record, (b) state AGs who may pick up the consumer-finance framing, (c) class-action plaintiffs’ bar watching this space.

5.3 If you’re an OO in any state:

  1. Get a third-party transportation lawyer to review any lease, lease-purchase, or dispatch agreement BEFORE signing.
  2. Verify walk-away equity on any LPA (if it’s $0, walk away from the LPA, not from the contract).
  3. Watch the FMCSA regulatory agenda (Unified Agenda, April and October) for any Truth-in-Leasing NPRM.

6. Sources (Part 3)

CA-prong-B workaround / dispatch-carrier agreement

  1. TruckLeap — Sample Dispatch-Carrier Agreement (April 29, 2026)
  2. USA Trucker Choice — Dispatch Service Agreement: What to Include (Mar 8, 2026)
  3. US Legal Forms — California Owner Operator Agreement Template
  4. Bonafide Trucking Solutions — Owner-Op Dispatch in California

TLTF / CFPB / Bonta (critical for NPRM prediction) 5. Landline Media — CFPB ordered to ‘cease’ activity (Feb 11, 2025) 6. Landline Media — California’s AB5 upheld by Ninth Circuit (May 22, 2025) 7. FreightWaves — OOIDA makes now-solo case (April 22, 2025) 8. California Trucking Association v. Bonta (9th Cir. 2025) — full PDF 9. CFPB Staff Report — Observations on Truck Lease-Purchase Agreements (Jan 17, 2025) 10. TheTrucker.com — FMCSA task force slams truck leasing practices (Jan 23, 2025) 11. Overdrive Online — Task Force wants to end carriers’ truck lease-purchase programs 12. FreightWaves — FMCSA panel recommends ban on truck lease-purchase contracts (Jan 22, 2025)

NPRM prediction context 13. FMCSA — Notices and Rulemaking Documents 14. FMCSA — TLTF landing page 15. FMCSA — TLTF taxonomy 16. TrueNorthFleet — TLTF January 2025 Findings (Jan 30, 2025) 17. Truck Driver News — Lease Purchase Must Be Outlawed (Jan 22, 2025) 18. CCJ — Task force calls for end of carriers’ lease-purchase programs (Jan 23, 2025)

Federal regs primary 19. eCFR 49 CFR Part 376 20. eCFR 49 CFR §376.12 21. eCFR 49 CFR §376.22

State misclassification cross-reference 22. CullenLaw — AB 5/AB 2257 23. altLINE — California’s AB5 Law 24. Scura — NJ Worker Classification Rules (Jun 5, 2026) 25. Marzano HR — NJ ABC Test Rule 2026 (May 12, 2026)

7. Verification Notes (Part 3)

  • 49 CFR Part 376 verbatim text captured from eCFR XML API in Part 1. Unchanged.
  • Bonta ruling: 9th Cir. affirmed May 22, 2025. Verified via Landline + FreightWaves + case PDF.
  • CFPB cease order: Feb 11, 2025. Verified via Landline article citing Associated Press and direct observation of CFPB homepage returning “404: Page not found.”
  • TLTF findings: Jan 16, 2025 report submitted to Congress. Verified via TrueNorthFleet, FreightWaves, Truck Driver News, CCJ, Overdrive.
  • Dispatch-carrier agreement structure: pattern verified via TruckLeap (April 29, 2026) and USA Trucker Choice (Mar 8, 2026).
  • NPRM prediction: my analysis based on (a) TLTF recommendations, (b) gutted CFPB, (c) FMCSA’s signaled scoping in 2026 stakeholder meetings, (d) Trump deregulatory executive orders (DOL rule rescinded March 2025). Confidence levels labeled in §4.
  • This is research, not legal advice. The dispatch-carrier template in §2 is a reference structure, not a substitute for a CA transportation attorney’s review.

8. TL;DR table

Question Answer
Can I keep leasing on a CA carrier after AB-5? Risky. 9th Circuit ruled against you May 2025.
What’s the CA-safe structure? Dispatch-carrier agreement + your own MC + independent insurance + no exclusivity + no forced dispatch.
What about NJ (effective Oct 1, 2026)? Same restructuring recommended.
What about NY / MA? Same ABC-test risk. Same dispatch-carrier pivot applies.
Will the FMCSA Truth-in-Leasing NPRM ban lease-purchase? Almost certainly not, given (a) gutted CFPB, (b) Trump deregulatory posture. Watch for Q4 2026 ANPRM.
Will the NPRM include disclosure requirements? Very likely (record-keeping, plain-language disclosures, whistleblower protection).
What to do RIGHT NOW? (1) Third-party lawyer review any lease/LPA. (2) If CA carrier with leased OOs, restructure to dispatch-carrier. (3) If OO in CA/NJ/NY/MA, run under own MC and use the dispatch-carrier template above.

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