Keeping operating credentials current

ez Explanations

Interstate regulated for-hire and private carriers sometimes experience serious difficulties due to lack of maintenance of their major operating credentials. The most serious result can be an "Out of Service" ruling and being shut down.

Once obtained, credentials must be kept up to date to reflect changes in your information. The most common errors are caused by:

An out-of-date address,
A company name change, and/or
A significant change in ownership (e.g., mergers and acquisitions).

None of these have simple fixes; each may require multiple filings.

Scope

For-hire and private motor carriers must regularly check and update operating credentials, especially after a change in company name, address, or ownership.

Regulatory citations

49 CFR 365 — Rules governing applications for operating authority

Key definitions

For-hire carrier: A carrier that transports passengers, regulated property or household goods owned by others for compensation.
Private carrier: A carrier that transports its own cargo, usually as a part of a business that produces, uses, sells and/or buys the cargo that is being hauled.

Summary of requirements

The following checklists include common operating credentials to consider when changes occur related to company name, address, or ownership.

NAME CHANGE CHECKLIST

For hire	Private	Actions
X	X	Obtain state/provincial name change documentation.
X		File carrier name change information with the Federal Motor Carrier Safety Administration (FMCSA) for operating authority certificate/permit. See 365.413. The motor carrier (MC) number will not change. A new Certificate of Authority or Permit will not be issued, but a “Re-entitlement Decision” will be provided. This document should be attached to original operating authority. Online filing not available.
X		File updated Form BOC 3 with FMCSA (designate process agents).
X	X	Insurance company to file updated insurance document with FMCSA. All for-hire and hazardous material private carriers obtain updated MCS90/90B per 387.9.
X	X	File modification of USDOT number (MCS 150 or MCS 150B hazmat safety permit). Online filing available.¹
X	X	Transfer DOT drug/alcohol testing service to reflect new name.
X	X	Obtain/transfer International Registration Plan (IRP) account.
X	X	Obtain/transfer International Fuel Tax Agreement (IFTA) account.
X	X	Obtain/transfer CT, NY, KY, NM, OR weight/distance tax accounts.
X	X	Change name on other state accounts (intrastate authority, etc.) if applicable.
X	X	Change name on provincial safety registration if applicable.
X	X	Change name on vehicle.
X	X	Placarded hazmat carriers required to register with the Pipeline and Hazardous Materials Safety Administration (PHMSA) must submit an amended registration statement to PHMSA within 30 days of name change.

ADDRESS CHANGE CHECKLIST

Fir hire	Private	Actions
X		File carrier address change information with FMCSA (365.413 authority). Online filing not available.
X		File updated Form BOC 3 with FMCSA (designate process agents).
X	X	File modification of USDOT number (MCS150 or MCS150B). Online filing available.¹
X	X	Notify DOT drug/alcohol testing service of new address.
X	X	Modify IRP account.
X	X	Modify IFTA account.
X	X	Modify CT, NY, KY, NM, OR weight/distance tax accounts.
X	X	Change address on other state accounts (intrastate authority, etc.) if applicable.
X	X	Change address on provincial safety registration if applicable.
X	X	Placarded hazmat carriers required to register with PHMSA must submit an amended registration statement to PHMSA within 30 days of address change.

OWNERSHIP CHANGE CHECKLIST

For hire	Private	Actions
X		File authority transfer information with FMCSA (Subpart D of Part 365).
X		File OP-1 form with required attachments (per 365.405).²
X	X	File new insurance (for hire BMC91/91X, BMC 34). All for-hire and hazardous material private carriers obtain updated MCS 90/90B per 387.9.
X		Update Form BOC 3 with FMCSA (designate process agents).
X	X	Obtain new USDOT number if acquiring owner does not have one.
X	X	Obtain Unified Carrier Registration (UCR) registration (if acquiring owner not registered under new US DOT number).
X	X	Transfer DOT drug/alcohol testing service to reflect new USDOT number.
X	X	Check with base jurisdiction regarding need for new IRP/IFTA accounts. Change in Federal Employer Identification Number (FEIN) usually requires new accounts.
X	X	Obtain/transfer CT, NY, KY, NM, OR weight/distance tax accounts.
X	X	Obtain other state accounts as necessary (intrastate authority, etc.).
X	X	Obtain necessary provincial safety registration.
X	X	Change name/US DOT number on vehicle.

¹ The MCS-150 form(s) may be discontinued in 2025, if/when a new online process is implemented.

² The OP-1 form may be discontinued in 2025, if/when a new online process is implemented.

['Registration and Permits - Motor Carrier', 'Fleet Taxes', 'Operating Authority']

['Brokers and brokering freight - Motor Carrier', 'Designation of process agents (BOC-3)', 'International Fuel Tax Agreement (IFTA)', 'International Registration Plan (IRP)', 'Private carrier authority', 'Fleet taxes', 'Freight forwarder', 'For-Hire Carrier Authority']

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