E-2 Visa Business Plan for a Moving Company: What Officers Look For

The INA 101(a)(15)(E)(ii) E-2 classification requires an active, bona fide enterprise — not a passive investment. A moving and relocation business clears that threshold clearly: it involves ongoing operations, physical assets, a workforce, and revenue from delivering a service. Under 9 FAM 402.9-4(B)(4), a bona fide enterprise must be a real, operating commercial or entrepreneurial undertaking. A moving company with executed contracts, operating authority, and staff satisfies that standard.

The enterprise also needs to be non-marginal under 9 FAM 402.9-6(B): it must have the present or prospective capacity to generate significantly more than a marginal living for the investor and family, typically demonstrated through U.S. job creation or substantial revenue. A moving company that employs drivers, movers, and dispatchers — common for even a mid-size local operation — is well positioned here. The business plan must make that capacity explicit rather than leaving it implicit in the revenue projections.

The proportionality test under 9 FAM 402.9-4(B)(3) does not impose a statutory minimum, but adjudicators measure the investment against the total cost of establishing or acquiring the enterprise. For a moving company, that total cost is driven by vehicles and equipment, and the investment must be substantial relative to that total.

A local residential moving operation might require one or two box trucks ($30,000–$80,000 each used, $80,000–$150,000 new), equipment such as dollies, blankets, and straps, licensing and operating authority from the Federal Motor Carrier Safety Administration (FMCSA) and the relevant state authority, commercial auto and cargo liability insurance, a lease for warehouse or staging space, and initial working capital. Investors purchasing an existing moving company must use a defensible business valuation — typically an income approach or asset-based approach — and the investment amount must reflect the purchase price actually paid.

The capital must be at-risk under 8 CFR 214.2(e)(12): irrevocably committed to the enterprise and subject to loss if the business fails. Funds sitting in the investor's personal account are not at-risk. Down payments on vehicles, equipment deposits, insurance premiums paid, and lease security deposits all qualify once paid. The business plan must reconcile the use-of-funds table with the exhibits (invoices, purchase agreements, bank wire records) so the officer can match every dollar to a documented commitment.

• Itemize every startup expense: each vehicle (VIN and purchase price), equipment inventory, FMCSA registration fees, state authority fees, insurance premiums, lease deposit, and working capital reserve
• Show the investment-to-total-cost ratio explicitly — for lower-cost businesses the investor typically needs to cover a majority of the enterprise cost
• If acquiring an existing moving company, include the valuation report, purchase agreement, and transfer of operating authority documentation
• If any portion was financed, show the loan documents and confirm the investor bears personal liability, not just the enterprise

A moving company that transports household goods across state lines is regulated as a motor carrier under 49 U.S.C. Chapter 135 and must obtain a USDOT number and broker or carrier authority from the FMCSA before operations begin. Intrastate-only movers are regulated by the relevant state utility commission or transportation department. The business plan should name the specific licenses and authority the enterprise will hold or has already obtained — not as boilerplate, but because the presence of real regulatory commitments is evidence of a bona fide enterprise.

The plan should also address insurance requirements: FMCSA requires minimum cargo and liability coverage for interstate household goods movers, and state minimums apply for intrastate operations. These insurance costs belong in the startup cost breakdown and the operating expense line of the financial projections. An officer reviewing the plan expects to see these regulatory realities reflected in the numbers; a plan that omits them raises credibility questions.

For a moving company, the staffing plan is one of the strongest tools available to satisfy non-marginality. A residential moving crew typically requires at least two people per truck, plus dispatch and customer service capacity if the investor is managing rather than laboring. A plan projecting one truck and a two-person crew at launch, growing to three trucks and a team of eight within three years, tells a concrete non-marginality story.

The staffing section should identify positions, wage rates, full-time versus part-time status, and the hiring timeline tied to the revenue projections. Under 9 FAM 402.9-6(B), job creation for U.S. workers who are not relatives of the investor is the clearest evidence that the enterprise will support more than a marginal living. Name the positions — driver, mover/helper, dispatcher, office manager — and specify whether they are W-2 employees or contracted labor (for E-2 purposes, employees are generally more persuasive than independent contractors).

If the investor intends to drive or work alongside crew at launch, the plan must distinguish this temporary labor involvement from the ongoing management and direction role. Officers apply the develop-and-direct requirement under 8 CFR 214.2(e)(1): the investor must be coming to develop and direct the enterprise, not primarily to perform manual labor. A credible plan acknowledges early-stage owner involvement while describing the transition to a management role as the business scales.

• Include a hiring timeline tied to revenue milestones — Year 1: 2 drivers + 1 dispatcher; Year 2: add second crew; Year 3: office manager hired
• State wage rates for each position and whether they are W-2 or 1099
• Clearly separate the investor's management responsibilities from any initial hands-on involvement
• Show that U.S. workers (non-family members) will be employed — this is the core non-marginality evidence for a service business

Revenue projections for a moving company are grounded in move volume, average job revenue, and market demand. A residential local move in a mid-size metropolitan area might average $700–$1,500 depending on size and distance; a long-distance move will be considerably higher. The plan should derive revenue from a realistic estimate of weekly job capacity per truck rather than from an undifferentiated market-size figure. If the company can complete six local moves per week per truck at an average of $950, the first-year gross revenue range is calculable and defensible.

Operating expenses to model include fuel, vehicle maintenance and repairs, insurance (commercial auto, cargo liability, general liability, workers' compensation), labor, dispatch software or CRM, marketing and lead generation, vehicle payments or depreciation, and any warehouse or lot lease. Net income after owner compensation should be projected to grow substantially beyond the investor's living costs, consistent with the non-marginality requirement.

The projections must include a startup balance sheet, monthly or quarterly cash flow for at least years one through three, annual income statements for five years, and a break-even analysis identifying the move volume required to cover fixed and variable costs. These schedules must be internally consistent: the revenue assumptions must align with the staffing schedule, and the operating expense assumptions must reflect the actual costs stated in the startup cost breakdown.

The develop-and-direct requirement under 8 CFR 214.2(e)(1) and 9 FAM 402.9-4(B)(7) is frequently mishandled in service-business plans. The investor cannot satisfy this requirement by being a passive owner or by designating a U.S.-based general manager to run the business while the investor serves a nominal oversight role. The investor must hold the executive or managerial position that gives them control over the enterprise's direction and operations.

For a moving company, this means the investor typically serves as the owner-operator with specific management responsibilities: setting pricing strategy, entering contracts with corporate clients or building partnerships with real estate agents, managing driver scheduling and customer relations, and directing the expansion timeline. The plan should describe these responsibilities concretely. If a co-owner or manager holds significant operational responsibility, the plan must show that the investor retains decision-making authority over the enterprise's direction — particularly if the investor holds exactly or near fifty percent ownership, which requires the plan to establish actual control rather than just majority stake.

The market analysis should identify the specific metropolitan area, the volume of residential and commercial moves in the target geography, the competitive landscape, and the investor's differentiation strategy. Local moving is a fragmented market with a mix of large national brands (United Van Lines, Allied, Mayflower), regional mid-size operators, and solo owner-operators. The business plan need not claim a large market share to satisfy the non-marginality test — it needs to show that a realistic market exists for the enterprise's capacity.

Cite verifiable sources: U.S. Census Bureau data on residential mobility rates for the target market, Bureau of Labor Statistics data on moving-industry employment and revenue, or IBISWorld industry reports. A market analysis that makes up an industry-size figure creates a credibility problem; one that cites a source and draws a conservative inference from it does not.

Understating or mischaracterizing the investment is the most common problem. Officers see plans that list 'vehicle purchase: $50,000' without specifying whether the truck is bought or leased, without providing the purchase agreement or dealer invoice, and without reconciling that figure against the source-of-funds evidence. Every capital outlay must tie to a document.

A second issue is projecting all revenue from owner-operated moves, which signals that the enterprise's income depends on the investor's personal labor rather than on capital deployment and a workforce. The financial projections should show how revenue grows as additional trucks and crew are added, so the business's scale depends on the investment rather than solely on the investor's personal productivity.

A third problem is omitting FMCSA licensing and insurance costs from the financials. Officers reviewing a moving company plan expect to see DOT registration costs, FMCSA authority fees, commercial auto insurance premiums (which are materially higher than personal auto premiums), and cargo liability insurance. A plan that lacks these is either incomplete or not modeling a real moving operation.