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Compliance

MVR monitoring

The motor vehicle record is the cheapest piece of risk information you will ever buy, and the annual review of it is one of the most commonly botched documents in the file.

At hire and every year after

Within 30 days of hiring a driver, you obtain a motor vehicle record from every state that licensed them in the preceding three years. Then, at least once every twelve months, you obtain another one and you review it.

The review is the requirement. The MVR is just the input. 49 CFR 391.25 asks you to consider the driver's record and determine whether they still meet minimum qualification standards, and then to document that determination with a signature and a date.

Why unsigned reviews fail

An MVR sitting in a file proves you bought a record. It does not prove anyone read it. The signed, dated note of review is the only evidence that a qualified person looked at the driving history and made a judgment.

This is the single most common driver-file finding we see. The carrier did the work. They pulled the record, someone looked at it, the driver was fine. Nobody signed anything, so on paper it never happened.

Annual pulls versus continuous monitoring

The regulation sets a floor of once every twelve months. The risk does not operate on that schedule. A driver can pick up a DUI in February and keep driving your truck until their review comes up in November, and you would have no way of knowing unless they told you, which 391.27 requires them to do and which does not always happen.

Continuous monitoring closes that window by alerting on activity as it is reported rather than annually. It is not required. It is the difference between compliance and actually managing the risk, and insurers increasingly ask about it.

MVR obligations

RequirementRuleTiming
MVR from each state licensing the driver in the past 3 years391.23Within 30 days of hire
Annual MVR391.25At least every 12 months
Annual review of driving record, signed and dated391.25At least every 12 months
Driver's certificate of violations391.27At least every 12 months

Questions

How often do I have to pull an MVR?+

At hire, from every state that licensed the driver in the previous three years, and then at least once every twelve months for the annual review.

Does the annual review have to be signed?+

Yes, and this is where most files fail. The review must be documented with a signature and date showing a qualified person evaluated the record and determined the driver still meets the standards.

Is continuous MVR monitoring required?+

No. The rule sets an annual floor. Continuous monitoring exceeds it, and it is the difference between finding out about a disqualifying violation in February rather than eleven months later.

This page summarizes federal regulations for general information. It is not legal advice, and the regulations change. Verify current requirements against the Federal Motor Carrier Safety Regulations or ask us.

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Want this off your desk?

We will review your current files and tell you what is missing, at no charge. If you are in better shape than you think, we will say so.