Background

In Order Instituting Investigation (I.) 00-09-003, the Commission opened an investigation into Ace's operations based on allegations by the Commission's staff that Ace had violated the Household Goods Carrier's Act, the Commission's Maximum Rate Tariff 4, and General Orders 100-M, 136-C, 139-A, and 142. The specific allegations are reprinted in Appendix A. In summary, the allegations were that Ace:

· failed to resolve loss and damage claims in a timely manner, and to maintain a claims register;

· did not provide each customer a written Agreement for Moving Services before the move began;

· did not show required information, including a Not To Exceed Price on moving documents;

· failed to provide Commission employees access to its records;

· permitted inadequately trained and supervised crews to perform moving services;

· refused to unload belongings unless customers paid amounts in excess of the estimate; and

· falsified an insurance document.

On March 9, 2001, Ace submitted a document entitled "Response to the Order Instituting Investigation." In that document, Ace admitted that it had violated several requirements in the early stages of its operations but that it had corrected those violations, and was now in compliance.

On April 13, 2001, hearings were held before the assigned Administrative Law Judge. Consumer Services Division (CSD) presented four witnesses, and Unikov testified for respondents.

CSD filed and served its post hearing brief on June 8, 2001.