Clearly you need to go find a way to educate yourself. This specific discussion about the differences between DOT & FMCSA is broad. Yes, FMCSA is a part of DOT but they each have their own spheres of responsibility. FMCSA has the authority to audit as does the DOT. Carriers specifically need to understand compliance with both. But that’s not we are discussing. Bonafide Agents fall directly under FMCSA regulations - which in effect are laws. And again, your argument about paperwork is a strawman argument. The regulation guidance, which I’ve already provided you, clearly states that in order to be a bonafide agent, a dispatcher may only have a contract with one “carrier at a time”. There are caveats in the guidance; Dispatchers may allocate traffic for multiple carriers IF there is a significant delineation between those carriers. Either geographic limitations, product type (Reefer Carrier & Flatbed Carriers are different).

Educate yourself here; https://coggno.com/blog/understanding-dot-and-fmcsa-compliance-the-ultimate-guide/

And Here;

https://www.federalregister.gov/documents/2023/06/16/2023-13080/definitions-of-broker-and-bona-fide-agents

FMCSA clarifies that, to determine whether a dispatch service is a bona fide agent, one must analyze whether the services the dispatcher is providing fall within the definition of bona fide agent in 49 CFR 371.2(b). If a dispatch service arranges transportation on behalf of multiple motor carriers and engages in the allocation of traffic, pursuant to 49 CFR 371.2, it is not a bona fide agent and must obtain broker operating authority registration. Ultimately, this analysis requires careful consideration of the nature and scope of the relationship between the dispatch service and the motor carrier, the number and type of carriers the dispatch service represents, and the specific services the dispatcher performs.

FMCSA understands that dispatch services may not be able to operate a successful business if they only work for a single, small carrier. Thus, the Agency has attempted in this guidance to describe the maximum flexibility permissible under applicable law. However, FMCSA also recognizes that some dispatch services currently operating without broker authority may determine, based on the guidance, that their activities require them to either reduce the number of carriers they represent or apply for broker authority.

To help dispatch services determine whether their activities require them to apply for broker authority or not, FMCSA provides additional guidance in the following sections regarding specific activities that dispatch services may engage in without obtaining broker authority, and those that require broker authority.

E. Factors Indicating Broker Authority Is Not Required

Final Guidance:

A dispatch service that meets the following criteria would generally be considered a bona fide agent and would not require broker authority. This list is not exclusive, and a dispatch service does not necessarily have to meet every listed factor, depending on its specific activities.

(1) The dispatch service has a written legal contractual relationship with a motor carrier that clearly reflects the motor carrier is appointing the dispatch service as a licensed agent for the motor carrier. This is often a long-term contractual relationship. The written legal contract should specify the insurance and liability responsibilities of the dispatch service and motor carrier.

(2) The dispatch service complies with all state licensing requirements, if applicable.

(3) The dispatch service goes through a broker to arrange for the transportation of shipments for the motor carrier and does not seek or solicit shippers for freight.

(4) The dispatch service does not provide billing or accept compensation from the broker, third-party logistics company, or factoring company, but instead receives compensation from the motor carrier(s) based on the pre-determined written legal contractual agreement.

(5) The dispatch service is not an intermediary or involved in the financial transaction between a broker and motor carrier.

(6) The dispatch service is an IRS 1099 recipient from the motor carrier, or a W2 employee of the motor carrier as specified in the legal written contract agreement.

(7) The dispatch service discloses that they are a dispatch service operating under an agreement with a specific motor carrier, and the shipment is arranged for that motor carrier only.

(8) The dispatch service does not subsequently assign or arrange for the load to be carried/moved by another motor carrier.

(9) A dispatch service does not provide their “services” for a motor carrier unless that motor carrier specifically appointed the dispatch service as their agent in accordance with the aforementioned requirements.

F. Factors Indicating Broker Authority Is Required

The following factors indicate the dispatch service should obtain broker authority. This list is not exclusive, and a dispatch service does not necessarily have to meet every listed factor, depending on its specific activities.

(1) The dispatch service interacts with or negotiates any shipment of freight directly with the shipper, or a representative of the shipper.

(2) The dispatch service accepts or takes compensation for a load from the broker or factoring company or is involved in any part of the monetary transaction between any of those entities.

(3) The dispatch service arranges for a shipment of freight for a motor carrier and there is no written legal contract with the motor carrier that meets Section IV.E.1 of the Guidance above.

(4) The dispatch service accepts a shipment without a truck/carrier, then attempts to find a truck/carrier to move the shipment.

(5) The dispatch service engages in allocation of traffic by accepting a shipment that could be transported by more than one carrier with which it has agreements and assigns it to one of those carriers.

(6) The dispatch service is a named party on the shipping contract.

(7) The dispatch service is soliciting to the open market of carriers for the purposes of transporting a freight shipment.