On December 8, 2025, the Federal Transit Administration issued a Special Directive to Mayor Brandon Johnson and the Chicago Transit Authority. It found the CTA had failed to maintain a safe operating environment for workers and passengers and had failed to implement adequate mitigations to address a years-long pattern of elevated assaults. CTA's violent crime rate, the FTA noted, was nearly four times the national average.

On December 8, 2025, the FTA issued a Special Directive to Mayor Brandon Johnson and the Chicago Transit Authority. The directive found that the CTA had failed to update its Public Transportation Agency Safety Plan and had failed to maintain a safe operating environment for workers and passengers, including failing to implement adequate mitigations to address a years-long pattern of elevated assaults. CTA's violent crime rate, the FTA noted, was nearly four times the national average.

The FTA did not threaten to withhold federal funds because the CTA was not spending on security. It threatened to withhold funds because the CTA was spending, and it was not working.

What Half a Billion Bought

The complete enforcement cost picture

Parts I and II of this investigation documented $251 million in private security contracts: Monterrey Security Consultants, Inter-Con Security Systems, and Action K-9 Security Services. The Office of Budget and Management's public appropriations records add the other half of the picture.

The City of Chicago pays CPD for transit enforcement through a dedicated CTA Detail appropriation, funded by the CTA. That appropriation tells its own story.

Year
CPD CTA Detail
Private Security
Year Total
2018
$15,649,725
$0
$15,649,725
2019
$10,754,000
$0
$10,754,000
2020
$10,754,000
$0
$10,754,000
2021
$10,754,000
Monterrey + Inter-Con contracts begin
$10,754,000 + contracts
2022
$10,754,000
Action K-9 $55M signed Aug 2022
$10,754,000 + contracts
2023
$30,000,000
All contracts active
$30M + contracts
2024
$30,000,000
All contracts active
$30M + contracts
2025
$30,000,000
Action K-9 $89.6M signed Feb 2025
$30M + contracts
2026
$30,000,000
Monterrey terminated Apr 2026
$30M

The CTA Detail payment nearly tripled between 2022 and 2023 — from $10,754,000 to $30,000,000 per year — at precisely the moment the private security apparatus was in full operation. The CTA was not substituting private security for CPD. It was paying both, simultaneously, and increasing both.

$430M
Combined enforcement · 2018 to 2026

CPD CTA Detail appropriations 2018 to 2026: approximately $178.7 million. Private security contracts 2021 to 2025: $251 million. Combined enforcement apparatus: approximately $430 million. Actual fare evasion cash collected, per Department of Finance production dated May 4, 2026: $26,148.57. The CTA collected less than six cents for every thousand dollars it spent on enforcement.

What the Federal Government Said About It

The FTA Special Directive, December 8, 2025

The Action K-9 contract for $89.6 million was signed February 5, 2025 — ten months before the FTA Special Directive. The enforcement apparatus was not assembled in response to federal pressure. It was already in place when the federal government looked at it and found it inadequate.

FTA Special Directive · December 8, 2025 · Marcus J. Molinaro, Administrator
"CTA, the City of Chicago, and the State of Illinois have failed to meet this obligation. If CTA does not promptly increase its law enforcement presence, FTA will act, including by withholding federal funds... CTA's violent crime rate is nearly four times the national average... CTA failed to implement adequate mitigations to address a years-long pattern of elevated assaults on workers and riders and serious violent crime."
Source: FTA Special Directive, produced by City of Chicago Office of the Mayor under FOIA F136884, May 6, 2026

I want to be precise about what this document establishes. The FTA Administrator did not write to Mayor Johnson because the CTA had been passive about security. He wrote because the CTA had been active, visibly and expensively active, for years, and the outcome was a violent crime rate nearly four times the national average. The spending was not the solution. According to the federal regulator with grant authority over the CTA, the spending was part of the failure.

I disagree with the Trump administration on most things. I am saying plainly that on this specific question, the FTA was not wrong. If I were sitting in that chair, looking at $430 million spent on transit enforcement and a violent crime rate nearly four times the national average, I would have been angrier than Marcus Molinaro's letter suggests he was.

The Governance Finding

What the complete record shows

Three investigations across three parts have now produced a complete picture. A public transit authority serving one of the largest cities in the United States spent approximately $430 million on transit enforcement over eight years. It collected $26,148.57 in actual fare evasion revenue. It generated $34 million in largely uncollectable debt for 63,862 residents. Its board authorized a $26 million contract overspend and ratified it retroactively two and a half years later. It contracted with a firm whose co-founder is the brother of a federally convicted alderman, whose principals had donated $306,621 to Chicago politicians, including $3,500 to the Transportation Committee chair while the contract was active. It terminated that contract three weeks after renewing it, five days after the first FOIA request in this investigation landed.

And when the federal government reviewed what all of that spending had produced, it issued a Special Directive finding the CTA had failed.

The FTA did not threaten to withhold funding because the CTA was not spending on security. It threatened funding because the CTA was spending, approximately $430 million dollars, and it still was not working. Someone has to answer for that.

This investigation began as a simple fiscal question: does fare enforcement generate enough revenue to justify its cost? The answer, documented by the city's own data, is less than six cents per thousand dollars spent. The investigation that followed that answer produced federal corroboration, active referrals to the Illinois Attorney General, the Illinois Department of Transportation, and the Office of Executive Inspector General, two pending Public Access Counselor complaints, and 13 active FOIA requests with responses due through May 11.

The records are available. The data is sourced. The government referrals are in motion. The only question remaining is who in Chicago has the authority to act on what the data shows, and whether they will.

Michael Russo is the founder of PolicyTorque LLC. He is an independent policy researcher and journalist. He has no financial interest in any entity named in this investigation. Primary source documents including the FTA Special Directive, Department of Finance collection records, Department of Administrative Hearings adjudication data, CTA board ordinances, and Office of Budget and Management appropriations records are available upon request. Contact: michael@policytorque.com · 248-930-0117

Civil Rights Series · PUBLIC Transit