What is the difference between an MVR and a driving record?
"Driving record" is the everyday term; MVR (Motor Vehicle Record) is the state DMV product that delivers it. The MVR is the formal, machine-parseable extract of license status, conviction history, and license-action events that satisfies the §391.23 / §391.25 driver-qualification regulations. A "driving record" pulled from a DMV-self-service portal is the same dataset, but the carrier-pulled MVR carries the consent paperwork and audit trail the regulations require.
In casual usage, drivers say "driving record" and carriers say "MVR" — both refer to the state DMV record of license-eligible events. The difference is who pulls it and how. A driver self-pulling their own record on a DMV self-service portal pays the state fee and downloads a PDF for personal use. A motor carrier pulling an MVR through a screening agent goes through the DPPA permissible-purpose access channel (18 USC §2721) with documented driver consent.
For 49 CFR §391.23 pre-employment investigation, the regulation puts the obligation on the motor carrier. The §391.23(a) text requires the carrier to "make a written investigation" and "request" the driver's violation record from every state where the driver held a license during the prior 3 years. A driver-pulled record handed to the carrier doesn't establish the carrier's due diligence in the same way as an MVR pulled by the carrier or its authorized agent.
Beyond §391.23, the FCRA layer matters. When the MVR is bundled with PSP, CDLIS, or any other consumer report into an employment-screening package, FCRA §1681b(b)(2) requires a clear-and-conspicuous standalone disclosure plus the driver's written authorization before the report is pulled. A driver-pulled DMV record carries no such disclosure trail — the carrier still has to run a fresh MVR through the screening agent for the hire packet to be defensible.
Some industries (insurance, rideshare) pull "MVRs" too, but their permissible purpose is different (DPPA §2721(b)(6) insurance-underwriting use rather than the §2721(b)(9) employment-CDL use). The dataset is the same; the legal basis for access is what changes. Carriers should not mix purposes — an MVR pulled for insurance underwriting cannot be re-used for §391.23 pre-employment without a fresh DPPA + FCRA consent for the new purpose.