FMC Issues Final Rule Regarding Freight Forwarder And NVOCC Requirements

J. Michael Cavanaugh is a Partner and Eric Lee is an Associate in Holland & Knight's Washington D.C. office

The U.S. Federal Maritime Commission (FMC) issued its Final Rule in FMC Docket 13-05 on Nov. 3, 2015. The Commission's October vote in favor of issuing the Final Rule concluded a multiyear review and rulemaking that largely focused on 46 CFR Part 515.

Part 515 primarily provides the regulations governing freight forwarders, non-vessel operating common carriers (NVOCC) – U.S. or non-U.S. based – and other aspects of the ocean transportation intermediary (OTI) business. The full text of the FMC Docket 13-05 Final Rule is quite comprehensive. With the exception of the license renewal amendments, the OTI rule changes are effective Dec. 9, 2015.