MCS-150
Posted on November 4, 2013
Filed Under GENERAL
One of the several hundreds of regulations found in the Federal Motor Carrier Safety Regulations is 49 CFR 390.19, which requires a motor carrier to update its registration information with the Federal Motor Carrier Safety Administration (FMCSA) once every two years. If you have a USDOT number, you are a motor carrier, and subject to this requirement.
To determine when you must file your update, you must refer to your DOT number. The last digit of your number is the month in which you must file. The second to last number of the DOT number identifies if you must file in an odd numbered, or even numbered year. For example, if your DOT number is 921934, you must file your update by the end of April, 2015. Or, if your DOT number is 1632927, you must file your update by the end of July, 2014.
The registration may be filed by filling out the MCS-150 form, and mailing it to their office in Washington, DC. It may also be filled out electronically at their website, www.fmcsa.dot.gov. If you are filing the form electronically, you will need a PIN number in order to file the registration update. If you do not have a PIN number, they will mail one to you in 4-7 business days. You cannot get a PIN number from them any faster than that. If you lose your PIN number, it will take another 4-7 business days to get a new one, so don’t lose it.
The form itself asks for basic identifying information about a motor carrier such as name, address, and phone number. It also asks for the type of freight the carrier transports, as well as the number of trucks and drivers it has. FMCSA uses this information to keep tabs on the motor carrier, and to find the carrier if it needs to audit them. It also uses the truck and driver information to help score the carrier within its CSA system, which prioritizes motor carriers for audits. In the future, the information on the MCS-150 form identifying the number of trucks will also be used to ensure you have paid the correct amount of UCR fees.
This registration update regulation has been a requirement for many years, however, it was largely unenforced until recently. Now, as with many regulations, the FMCSA is taking a much harsher stance, and will occasionally mail penalties to motor carriers who have not updated their registration records.
FMCSA gets a list of carriers from its computers who have not updated their registration information on time. If FMCSA has evidence the carrier is still operating, and is not out of business, they may mail them a penalty for failing to update the registration. Typically, these penalties have been a few hundred dollars, but with the new MAP-21 law which was passed by Congress this summer, these penalties will probably now be at least $1,000.
To be fined for not filing the MCS-150 form is still uncommon, however, it is done. The penalties are issued in a fairly random and arbitrary fashion. Someone in one of the FMCSA local offices makes a decision to pump their enforcement statistics, at which point, claim letters for failing to update the MCS-150 forms are mailed to all the offending motor carriers.
Occasionally the FMCSA will mail you a reminder notifying you need to update your MCS-150 form, but usually it does not. If you do not update your registration information, FMCSA holds you responsible, either way. Also, if you update your registration information at some point prior to the month and year prescribed by your DOT number, you still must file it again when the rules demand. For example, a motor carrier’s number is 1632927. They update their registration information in December, 2013, because they bought 10 new trucks. They still need to file the MCS-150 form again in July, 2014.
Make sure your information is up-to-date with FMCSA. It could save you some money.
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