# FastDriverScreening > DOT driver screening - five packages from $40 (MVR Basic) to $100 (DOT Pre-Employment, the full pre-hire stack: MVR + CDLIS + PSP + FMCSA Clearinghouse pre-employment query). Same-day digital delivery. Optional $25 Driver Qualification (DQ) File template - the same one our compliance team uses internally to onboard drivers. FastDriverScreening is operated by Fast Filing Group LLC and is part of the Fast Trucking Compliance ecosystem (BOC-3 filing, UCR registration, MCS-150 updates, Form 2290 HVUT, new operating authority, reinstatement). Reports are pulled from the issuing-state DMV, AAMVA CDLIS, FMCSA PSP, and the FMCSA Drug & Alcohol Clearinghouse - the same sources enterprise screening services use - and delivered as PDFs that meet 49 CFR §391.23 (pre-hire), §391.25 (annual review), and §382.701 (Clearinghouse pre-employment + annual queries) audit standards. ## What we sell - **MVR Basic - $40.** Single Motor Vehicle Record from the issuing-state DMV. Best for non-CDL commercial drivers and §391.25 annual driver-record reviews. - **MVR + CDLIS - $60.** State MVR plus AAMVA CDLIS cross-state CDL lookup. Required on every CDL hire under 49 CFR §391.23(m)(2). Surfaces undisclosed CDLs from other states that a single-state MVR cannot catch. - **DOT Hire-Ready - $80.** MVR + CDLIS + FMCSA PSP (Pre-Employment Screening Program: 5-year crash history + 3-year roadside-inspection history). Used to vet candidates before formal offer/hire - no Clearinghouse consent required. - **DOT Pre-Employment - $100** *(most popular, mandatory at hire)*. Full pre-hire stack: MVR + CDLIS + PSP + FMCSA Clearinghouse pre-employment query. The Clearinghouse pre-employment query is required under 49 CFR §382.701(a) before a CDL driver's first dispatch - operating without it is a documented FMCSA violation. Driver e-signs Clearinghouse consent at clearinghouse.fmcsa.dot.gov; report lands within 1 business day. - **Annual Refresh - $60.** MVR + Clearinghouse limited annual query. Required every 12 months on every CDL driver under §382.701(b), pairs naturally with the §391.25 annual MVR review. One-time charge per driver per year (not a Stripe Subscription - purchase again at the next anniversary). - **DQ File Template - +$25, optional.** Available as an add-on at checkout on every package. The Driver Qualification File template our compliance team uses internally, packaged as a fillable PDF + editable Word doc covering 49 CFR §391.51. One-time purchase, reusable across every driver. ## Required driver fields Five fields off the front of any U.S. driver's license: 1. First name 2. Last name 3. Driver's license number 4. Expiration date 5. State of issue Plus the carrier's name, email, phone, and a written-consent attestation (driver consent is required by the federal DPPA, 18 USC §2721, and the FCRA). ## Turnaround Most reports come back in minutes. A handful of states require a manual lookup and can take up to one business day; we email the moment results land. ## Cross-spoke ecosystem - BOC-3 filing - https://www.fastboc3filing.com (process-agent designation) - UCR registration - https://www.fastucrfiling.com (annual unified carrier registration) - MCS-150 update - https://www.fastmcs150filing.com (biennial USDOT update) - Form 2290 HVUT - https://www.fast2290filing.com (heavy vehicle use tax) - New authority - https://www.fasttruckauthority.com (USDOT/MC operating authority) - Reinstatement - https://www.fastreinstatementfiling.com (revoked-authority recovery) - Hub - https://www.fasttruckingcompliance.com (compliance vault + dashboards) ## Frequently asked questions ### What screening packages do you offer? Five packages spanning the full DOT pre-hire stack. (1) MVR Basic - $40, single Motor Vehicle Record, best for non-CDL drivers and §391.25 annual reviews. (2) MVR + CDLIS - $60, adds the AAMVA cross-state CDL check required at every CDL hire under §391.23. (3) DOT Hire-Ready - $80, adds FMCSA PSP (5-yr crash + 3-yr inspection history) for candidate vetting before formal hire. (4) DOT Pre-Employment - $100, the full pre-hire stack: MVR + CDLIS + PSP + FMCSA Clearinghouse pre-employment query (mandatory under §382.701(a) before a CDL driver's first dispatch). (5) Annual Refresh - $60, MVR + Clearinghouse limited annual query for §382.701(b) recurring compliance. ### How much does a single MVR cost? A single MVR is $40 flat (MVR Basic package). No per-state surcharges, no sign-up fees, no monthly minimums. Same-day digital delivery from the issuing-state DMV. ### Which package do I need before hiring a CDL driver? DOT Pre-Employment ($100). A complete CDL pre-hire file runs on four reports - MVR (§391.23(a)(1)), CDLIS (§391.23(m)(2)), a Clearinghouse pre-employment query (§382.701(a)), and PSP (voluntary under FMCSA rules, but the standard evidence of the safety-performance-history investigation) - and DOT Pre-Employment bundles all four. Buying anything cheaper means filling the gaps separately before the driver's first dispatch. ### What is the difference between DOT Hire-Ready and DOT Pre-Employment? DOT Hire-Ready ($80) gives you MVR + CDLIS + PSP - three reports you can pull without driver Clearinghouse consent. It's the candidate-vetting step. DOT Pre-Employment ($100) adds the FMCSA Clearinghouse pre-employment query, which requires the driver to e-sign a consent through the FMCSA Clearinghouse portal. The Clearinghouse query is the report you legally need before a CDL driver's first dispatch. ### How does Annual Refresh work? Annual Refresh ($60) bundles a yearly MVR (for §391.25 driver record review) with a Clearinghouse limited annual query (for §382.701(b) recurring compliance). Run it on every CDL driver every 12 months and your annual driver-side compliance is done in one click. It's a one-time charge, not a subscription - buy it again next year when the driver's anniversary rolls around. ### How quickly will I get the report? MVR, CDLIS, and PSP come back in minutes. The FMCSA Clearinghouse query lands within 1 business day after the driver e-signs consent in the Clearinghouse portal - that's the FMCSA system's response time, not ours. We email each report the moment it's delivered. ### What information is on an MVR? A Motor Vehicle Record lists the driver's license status, class and endorsements, expiration, restrictions, accidents, citations, suspensions, withdrawals, and any actions taken against the license over the FMCSA-required look-back period. It is the document you keep in the DQ File for §391.25 annual reviews. ### What does the FMCSA Clearinghouse query show? The pre-employment Clearinghouse query (limited consent) returns whether the driver has any unresolved drug or alcohol program violations on file in the FMCSA Clearinghouse - the federal database every CDL employer must check before hiring. The driver e-signs consent in their FMCSA Clearinghouse account and the query lands within 1 business day. Annual Refresh uses the same limited-consent query for the §382.701(b) recurring check. ### What is PSP and why include it? PSP - the FMCSA Pre-Employment Screening Program - is a federally-maintained database of every commercial driver's 5-year crash history and 3-year roadside-inspection history. It catches patterns (repeated HOS violations, brake-system failures, OOS orders) that a clean MVR would never surface. Both DOT Hire-Ready and DOT Pre-Employment include it. ### Do I need the driver's consent before pulling these reports? Yes - different consents for different reports. MVR + CDLIS need a written DPPA + FCRA driver authorization (our checkout collects this). PSP needs a written FMCSA-form consent (also collected at checkout). The FMCSA Clearinghouse query uses a digital handshake - the driver creates a Clearinghouse account at clearinghouse.fmcsa.dot.gov and approves your query in their portal. Packages that include any Clearinghouse component require this digital consent before we run the report. ### What if the driver's license is from a state your service does not cover? We cover all 50 states + D.C. Some states (e.g., Pennsylvania, Washington) require an extra step the system handles automatically. You see one package price - no per-state surcharges - regardless of issuing state. ### What is the Driver Qualification (DQ) File? A DQ File is the federally-required folder of documents every motor carrier must keep on each commercial driver they employ. It includes the application, MVRs, road test, medical card, drug-test records, and supervisor reviews. 49 CFR §391.51 spells out the contents. ### What does the $25 DQ File template add-on include? The same DQ File our compliance team uses internally to onboard drivers, packaged as a fillable PDF + editable Word doc. Includes the application for employment, road-test certificate, MVR review form, drug & alcohol consent, prior-employer verification, annual review checklist, and the driver certification of violations. Fill in the gaps for each driver and you have an audit-ready §391.51 file in minutes - without rebuilding the form from scratch every time. ### Is the DQ File template a one-time purchase or per-driver? One-time. You buy it once, save it, and reuse the template for every driver you onboard. We email a fillable PDF and an editable Word doc the moment your order completes. ### Who needs to pull MVRs and run CDLIS checks? Every motor carrier that employs commercial drivers - both CDL and most non-CDL commercial drivers. FMCSA requires an MVR before hiring (49 CFR §391.23) and an annual review (49 CFR §391.25). CDLIS is required for CDL holders under §391.23(m)(2). ### Are the reports admissible for FMCSA audits? Yes. We pull from the same state DMV, AAMVA CDLIS, FMCSA PSP, and FMCSA Clearinghouse sources used by enterprise screening services. The PDFs we deliver carry the issuing-source header and timestamp FMCSA auditors expect to see in the DQ File. ### Can I run an MVR on a driver who is not yet hired? Yes - that is the most common use case. A pre-hire MVR is required by §391.23 before the first day of operation. As long as you have the driver's signed consent, you can run the report. ### What is the §382.701(a) Clearinghouse pre-employment query rule? Since January 6, 2020, FMCSA requires every motor carrier to run a Clearinghouse pre-employment query on each CDL driver before that driver's first dispatch (49 CFR §382.701(a)). The query checks the federal Clearinghouse database for any unresolved drug or alcohol program violations on the driver's record. Operating a CDL driver without the query on file is a documented violation - the DOT Pre-Employment package handles it. ### What is the §382.701(b) annual Clearinghouse query? In addition to the pre-employment query, FMCSA requires every motor carrier to run a limited-consent Clearinghouse query on each CDL driver every 12 months (49 CFR §382.701(b)). The Annual Refresh package bundles this with the §391.25 annual MVR review so a year's worth of recurring driver compliance happens in one click. ### What is a driver qualification file service? A driver qualification (DQ) file service helps motor carriers maintain compliance with FMCSA 49 CFR Part 391 by creating, managing, and auditing the driver documentation every motor carrier must keep on file - driver application for employment, Motor Vehicle Records, medical examiner certificates, road-test certificates, drug and alcohol records, prior-employer safety-performance history, and annual driver reviews. Most DQ services offer secure electronic, audit-ready storage and automated tracking of expiring documents (CDL, DOT medical card, MVR review, driver list of violations) so a carrier passes a new-entrant safety audit, compliance review, or roadside DQ-file request without scrambling. FastDriverScreening provides the report-generation side (MVR, CDLIS, PSP, FMCSA Drug & Alcohol Clearinghouse) plus a $25 fillable §391.51 DQ-file template (PDF + editable Word) reused for every driver - the carrier still owns the DQ file but the screening reports and template come from us. ### What documents does FMCSA require in a DQ file? Under 49 CFR §391.51, every motor carrier must keep a DQ file on each commercial driver containing: the driver application for employment (§391.21), a Motor Vehicle Record from every state where the driver held a license in the past 3 years (§391.23), the road-test certificate or equivalent (§391.31), the annual MVR review (§391.25), the driver's list of violations from the prior 12 months (§391.27), and the current medical examiner's certificate or CDL with medical certification (§391.43). Prior-employer safety-performance history responses (§391.23) are kept in a separate secure investigation file under §391.53, retained for the duration of employment plus 3 years - not in the DQ file itself. For CDL drivers, FMCSA Drug & Alcohol Clearinghouse pre-employment and annual queries (§382.701) join the file. FastDriverScreening's $25 DQ-file template covers every required form. ### How do I run a DOT background check on a driver? A complete DOT pre-employment background check runs on four reports under FMCSA Part 391 + Part 382: a Motor Vehicle Record (MVR) from the state DMV (49 CFR §391.23), an AAMVA CDLIS cross-state CDL check that surfaces any license held in another state in the past 3 years (§391.23(m)(2)), an FMCSA Pre-Employment Screening Program (PSP) report covering the driver's 5-year crash history and 3-year roadside-inspection history (voluntary under FMCSA rules, but standard practice), and an FMCSA Drug & Alcohol Clearinghouse pre-employment query (§382.701(a)) that flags any unresolved drug or alcohol program violation in the federal database. The MVR, CDLIS, and PSP need written DPPA + FCRA driver consent collected at checkout; the Clearinghouse query uses a digital handshake the driver approves in their FMCSA Clearinghouse account. FastDriverScreening's DOT Pre-Employment package ($100) bundles all four with same-day delivery - running them piecemeal costs more. ### What is the fastest way to run DOT driver screening? The fastest DOT screening path returns MVR, CDLIS, and PSP in minutes - only the FMCSA Clearinghouse query takes up to 1 business day, because it waits on the driver e-signing consent in the federal portal. FastDriverScreening emails each report the moment it is delivered, so the practical speed lever is sending the driver their Clearinghouse consent request immediately: the rest of the pre-hire stack is done the same day. ### What makes a trusted DOT driver screening service? Three checks separate trusted DOT screening services from data resellers: reports pulled from the official sources (state DMV, AAMVA CDLIS, FMCSA PSP, FMCSA Clearinghouse) with the issuing-source headers auditors expect, flat package pricing with no per-state surcharges, and proper consent collection (written DPPA/FCRA authorization plus the Clearinghouse digital handshake). FastDriverScreening meets all three - packages from $40 to $100 flat, official-source PDFs with headers and timestamps, and every required consent collected before a report runs. ## Guide articles In-depth driver-screening and FMCSA-compliance guides covering MVRs, CDLIS, PSP, DQ files, and the §391 / §382 hiring rules. ### How to Read an MVR: A Line-by-Line Guide for Motor Carriers Source: https://www.fastdriverscreening.com/guides/how-to-read-an-mvr Category: MVR Published: 2026-04-15 Last Updated: 2026-05-01 Read time: 9 min Decode every section of a Motor Vehicle Record - license status codes, class and endorsements, restrictions, accidents, citations, and suspensions. TL;DR: A Motor Vehicle Record is the state DMV transcript that determines whether a CDL driver is qualified under 49 CFR §391.15. This guide walks every section in order - identification, status, class, endorsements, medical, accidents, convictions, administrative actions - so you can spot federal disqualifiers at a glance. Key takeaways: - The current license-status field is the single most important line - SUSPENDED, REVOKED, CANCELLED, or DISQUALIFIED is an automatic §391.15 stop. - CDL classes (A/B/C) and endorsements (H, N, P, S, T, X) determine what the driver can legally operate; restriction codes narrow that further. - Convictions must be classified under §383.51(b) major offenses or §383.51(c) serious traffic violations to know if a disqualification period applies. - Most states embed federal medical certification status on the MVR; an expired card disqualifies the driver under §391.41 regardless of license status. - A pattern of suspensions or preventable crashes is a §391.27 disclosure issue - document the pattern in the §391.51 file even when no current disqualification applies. A [Motor Vehicle Record (MVR)](/glossary/mvr) is the single most important document in a commercial driver's qualification file. It is the official transcript of a driver's license - pulled directly from the state Department of Motor Vehicles - and it is the document [FMCSA](https://www.fmcsa.dot.gov) auditors examine first when they open a [Driver Qualification (DQ) file](/glossary/dq-file). Yet most fleet managers never receive any formal training on how to read one. Sections look cryptic, status codes vary by state, and a single line buried at the bottom of the report can be the difference between a hire and a federally-mandated disqualification. This guide walks you through an MVR section by section, in the order it typically appears on the printed report, so you can spot the qualifying and disqualifying details at a glance. Use it as a reference next to any MVR you pull through FastDriverScreening. #### What an MVR actually is An MVR is the state DMV's official record of everything a single driver has done with their license over a defined look-back period. The Federal Motor Carrier Safety Administration (FMCSA) requires motor carriers to obtain one for every commercial driver before they are placed on the road, and again every twelve months. The legal authority for the requirement sits in two places - [49 CFR §391.23](/guides/391-23-vs-391-25) (pre-employment) and [49 CFR §391.25](/guides/391-23-vs-391-25) (annual review): > 49 CFR §391.23(a)(1) - Pre-employment investigation, MVR for the prior three years from every state where the driver held a license or permit. > 49 CFR §391.25(a) - Annual inquiry to obtain the driver's motor vehicle record from each state where the driver currently holds (or held during the prior twelve months) a motor vehicle operator's license. Because the record originates at the state DMV, MVR formatting varies state by state. The data points are largely the same, but the column order, header style, and short codes are not. The walkthrough below uses the most common conventions you will see across all 50 states. #### Section 1: Driver identification The top of every MVR contains the identifying information used to certify the document belongs to the right driver. Verify each field against the driver's application: - Full legal name (last, first, middle) - Date of birth - Driver license number - Issuing state - Address of record on file with the DMV If the address on the MVR does not match the address on the driver's application for employment, that is a flag - drivers are required to keep their license address current under most state laws, and a mismatch usually indicates either an out-of-date license or an attempt to obscure prior history. #### Section 2: License status This is the single most important field on the report. The status code tells you whether the license is currently valid - and if not, why. Common status codes include: - VALID / ELIGIBLE - license is in good standing, driver may operate the vehicle class shown - SUSPENDED - driving privilege has been temporarily withdrawn; the report will list the underlying reason and the reinstatement date - REVOKED - license has been terminated; the driver must reapply, often after a waiting period - CANCELLED - license has been administratively voided (often a paperwork issue) - DISQUALIFIED - a CDL-specific status applied when the driver has committed an offense that triggers FMCSA §383.51 disqualification - EXPIRED - license has passed its renewal date and is not currently valid A SUSPENDED, REVOKED, or DISQUALIFIED status disqualifies the driver from operating a commercial motor vehicle until the underlying issue is resolved. Hiring a driver in any of those states is a [§391.11](https://www.ecfr.gov/current/title-49/section-391.11) violation on its face - see our [decision tree on MVR violations](/guides/mvr-violations-decision-tree) for the full classification analysis. #### Section 3: License class and endorsements The class line tells you what kind of vehicle the driver is licensed to operate. The federal classes are: - Class A - combination vehicles with a GVWR of 26,001 lbs or more, towing a trailer over 10,000 lbs - Class B - single vehicles with a GVWR of 26,001 lbs or more - Class C - vehicles designed to transport 16+ passengers (including the driver) or hazardous materials in placardable quantities State non-CDL classes (often labeled D or "Operator") only authorize passenger-vehicle operation and are not sufficient for CDL-required driving. Endorsements are letter codes added to the license to authorize specific cargo or vehicle configurations: - H - Hazardous Materials (HazMat); requires a TSA security threat assessment - N - Tank vehicles - P - Passenger transport - S - School bus - T - Double/triple trailers - X - Combined HazMat and Tank Restrictions sit in a parallel column: - L - No air-brake-equipped CMV - E - No manual transmission CMV - M - No Class A passenger vehicle - N - No Class A or B passenger vehicle - O - No tractor-trailer CMV - V - Medical variance documentation required A driver hauling tankers without an N endorsement, or pulling doubles without a T endorsement, is in violation of §383.93 - and the carrier has just placed an unqualified driver behind the wheel. #### Section 4: Medical certification (where shown) Most state MVRs now show the driver's federal medical certification status, including the issue date, expiration, and self-certification category (non-excepted interstate, excepted interstate, etc.). A driver with an expired or downgraded medical card cannot legally operate a CMV regardless of their license status. #### Section 5: Accidents The accident block lists every crash on file with the DMV during the look-back period. Each entry typically shows the date, location, accident type (PI for personal injury, PD for property damage, F for fatal), and whether the driver was cited or found at fault. A pattern of preventable crashes is a §391.27 disclosure issue and a screening flag in its own right. #### Section 6: Citations and convictions This is where most disqualifying offenses appear. Each conviction line lists the date, the offense (often as a state-specific statute number), the conviction date, and any associated penalty. The offenses that matter most under federal law are the ones FMCSA classifies as serious, major, or disqualifying violations: > 49 CFR §383.51(b) - Disqualifying offenses include DUI/DWI, refusing a chemical test, leaving the scene of an accident, using a CMV in the commission of a felony, driving while disqualified, and causing a fatality through negligent operation. A first conviction triggers a one-year disqualification (three years if HazMat); a second triggers a lifetime ban. > 49 CFR §383.51(c) - Serious traffic violations include excessive speeding (15+ mph over), reckless driving, improper lane change, following too closely, texting while driving, and using a hand-held phone while driving a CMV. Two within three years triggers a 60-day disqualification; three within three years triggers 120 days. > 49 CFR §391.15 - General disqualification: a driver is disqualified while their CDL is under any state-imposed disqualification, while their privilege to drive is suspended or revoked, while they have an unsatisfied medical certification, or while they have been convicted of a felony involving the use of a CMV. When you see a violation on the MVR, your job is to (1) classify it under the FMCSA categories above, (2) check the conviction date against the look-back window, and (3) document the disposition in the DQ file. The [decision tree in our companion guide on MVR violations](/guides/mvr-violations-decision-tree) walks through every common scenario. #### Section 7: Suspensions, withdrawals, and administrative actions The bottom of the report typically lists every administrative action ever taken against the license, with start and end dates. Watch for: - Failure-to-appear suspensions (driver did not show up to court) - Financial responsibility suspensions (no insurance) - Child-support enforcement suspensions - Out-of-state withdrawal actions (another state imposed a suspension) A driver may show a current VALID status while still having a recent suspension on the record. The pattern matters as much as the current state. #### Bringing it together Reading an MVR cleanly is a learnable skill. Run through each section in order, flag any code you do not recognize, and check every disqualifying offense against the [§383.51](https://www.ecfr.gov/current/title-49/section-383.51) schedule before you put the driver on the road. The MVR you file under [§391.51](/guides/dq-file-checklist) is the document that proves you did the homework - make sure it is complete, dated, signed by the reviewer, and stored in the DQ file for the full retention period. When you are ready to pull a fresh MVR for a new hire, FastDriverScreening delivers the issuing-state record starting at $40 (MVR Basic), with $60 [MVR + CDLIS](/guides/cdlis-vs-mvr), $80 DOT Hire-Ready (adds [FMCSA PSP](/glossary/psp)), and $100 DOT Pre-Employment (adds the [Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough)) bundles available. Same-day digital delivery with a built-in [driver-consent attestation](/guides/dppa-driver-consent) that satisfies [DPPA](/glossary/dppa) requirements. ### The Complete DQ File Checklist Under 49 CFR §391.51 Source: https://www.fastdriverscreening.com/guides/dq-file-checklist Category: DQ File Published: 2026-04-15 Last Updated: 2026-05-01 Read time: 8 min Every document required in a Driver Qualification File, in the order to file them, with the federal authority for each item under 49 CFR §391.51. TL;DR: A 49 CFR §391.51 Driver Qualification File contains eleven required documents - application, MVR, prior-employer investigation, road test, medical certificate, National Registry verification, annual review, and more. Retain the file for the duration of employment plus three years. Key takeaways: - Every commercial driver - CDL or non-CDL - needs a §391.51 file with the eleven items listed in §391.51(b). - The §391.51(d) retention rule is duration of employment plus three years, even after termination. - Filing order matters: auditors check both whether documents exist and whether they appear in §391.51 sequence with valid dates. - The pre-employment MVR (§391.23) and CDLIS check happen before the driver's first day; the road test, medical certificate, and prior-employer investigation must be complete within 30 days of placement. - A reusable DQ File template eliminates the most common §391.51 audit findings - incomplete sections and missing reviewer signatures. The [Driver Qualification (DQ) file](/glossary/dq-file) is the federal paperwork trail that proves every commercial driver you employ is legally fit to operate the vehicle they have been assigned to. It is required for every CDL driver and most non-CDL commercial drivers, and it is the very first thing an [FMCSA](https://www.fmcsa.dot.gov) auditor asks to see during a compliance review. A missing document - or even a complete document filed in the wrong place - can trigger a violation on the audit report and roll directly into your CSA score. The contents are not optional and they are not negotiable. Every requirement is spelled out in 49 CFR §391.51, and the regulation lists each document by name. This guide walks through every required item, in the order it typically arrives during the hiring process, with a one-line summary of why FMCSA wants to see it. #### The legal foundation The §391.51 contents requirement reads, in summary form: > 49 CFR §391.51(a) - Each motor carrier shall maintain a driver qualification file for each driver it employs. The driver qualification file may be combined with the driver's personnel file. > 49 CFR §391.51(b) - The driver qualification file shall include the documents listed in paragraphs (b)(1) through (b)(11) of this section. > 49 CFR §391.51(d) - The motor carrier shall maintain the documents listed for as long as the carrier employs the driver and for three years thereafter. The retention rule is important: even after termination, you keep the entire DQ file for three years. Auditors routinely ask to see files for drivers who left the company eighteen months earlier. #### The complete checklist, in filing order Here is every document required by §391.51, in the order you collect them during the hiring process. For each item we have noted the regulation citation and the practical reason FMCSA wants it on file. ##### 1. Application for Employment The application is the first piece of paper in the file and the foundation for almost every verification step that follows. Required by §391.21, the application must include: - The driver's full name, address, date of birth - Names and addresses of every employer for the previous three years (ten years for CMV employment) - The reason for leaving each - Whether the driver was subject to FMCSA regulations or DOT-controlled-substance rules at each - A list of all motor vehicle accidents in the last three years - A list of all violations of motor vehicle laws (other than parking) for the last three years - Any denial, revocation, or suspension of any license, permit, or privilege to operate a motor vehicle - A signed certification by the driver that everything stated is true > 49 CFR §391.21(b) - Required application contents. The application is not just a hiring form - it is the source-of-truth document the rest of the file is built against. If the driver omits an employer here and you fail to catch it, you have just inherited their disclosure problem. ##### 2. Inquiry to State Agencies (Pre-Employment MVR) Before placing the driver on the road, you must obtain a Motor Vehicle Record from every state where the driver held a license or permit during the prior three years. > 49 CFR §391.23(a)(1) - Inquiry into the driver's driving record during the preceding three years. The [MVRs](/glossary/mvr) themselves go in the file, dated and signed by the reviewer. Pull the records through FastDriverScreening - same-day delivery from $40 (MVR Basic) per state, with the $60 [MVR + CDLIS](/guides/cdlis-vs-mvr) package satisfying the cross-state CDL requirement and $100 DOT Pre-Employment adding the [FMCSA Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough) mandated under [§382.701(a)](https://www.ecfr.gov/current/title-49/section-382.701). ##### 3. Inquiry to Previous Employers Within thirty days of the driver's placement on a CMV, you must investigate the driver's employment record for the prior three years (DOT-regulated employers) and document everything you found. > 49 CFR §391.23(a)(2) and (d) - Investigation into the driver's employment history. This includes verification of dates of employment, a copy of any drug and alcohol testing record under §40.25, accidents the driver was involved in, and any other DOT-regulated information the prior employer is required to disclose. ##### 4. Driver's Road Test Certificate (or Equivalent) Every driver must complete a road test administered by the carrier - or you must accept an equivalent in lieu of the test. The road test certificate goes in the file along with the form used during the test. > 49 CFR §391.31 (road test) and §391.33 (equivalent of road test, e.g., a CDL or a road test certificate from a previous carrier within the last three years). ##### 5. Medical Examiner's Certificate The driver's federal medical certification, signed by a certified medical examiner, must be in the file. Long-form examination results are not required unless the driver received an exemption or variance. > 49 CFR §391.43 (medical examination) and §391.41 (physical qualifications). ##### 6. Medical Examiner's National Registry Verification Carriers must verify that the medical examiner who signed the medical card is listed on the FMCSA National Registry of Certified Medical Examiners. Print or save the verification as part of the file. > 49 CFR §391.23(m) - Verification of medical examiner's national registry status. ##### 7. Driver's Certification of Compliance with Regulations The driver signs an annual statement listing all violations of motor vehicle laws (other than parking) for the prior twelve months, even if they were not cited. > 49 CFR §391.27 - Record of violations: the driver shall furnish a list of all violations annually, and the carrier shall retain the list in the qualification file. ##### 8. Annual Review of Driving Record Once a year, the carrier reviews the driver's driving record (the new MVR plus the §391.27 self-certification) and makes a written determination whether the driver remains qualified. See our [annual review checklist](/guides/annual-driver-record-review-checklist) for a step-by-step walkthrough. The signed review goes in the file. > 49 CFR §391.25 - Annual inquiry and review of driving record. ##### 9. Subsequent Annual MVRs Every twelve months, pull a new MVR and add it to the file. The MVR must be obtained from each state where the driver currently holds (or held in the prior year) an operator's license. > 49 CFR §391.25(a) - At least once every 12 months, the motor carrier shall make an inquiry to obtain the motor vehicle record of each driver. ##### 10. Documentation of Disqualifying Offenses If at any point a driver becomes disqualified - by suspension, revocation, conviction of a serious offense, or any §383.51 disqualifying offense - you must remove them from CMV operation immediately and document the action in the DQ file. > 49 CFR §391.15 - Disqualification of drivers. ##### 11. Termination Documentation When the driver leaves the carrier, document the date and reason for separation. Maintain the entire DQ file for three years from the date of termination per §391.51(d). #### Filing order matters Auditors do not just ask whether the documents exist - they ask whether they are in the order the regulation lists them and whether each is dated within the allowable window. A signed road-test certificate dated three months after the driver started operating the truck is itself a violation. Use the order above when you build each file, and file the documents chronologically within each section so the timestamps tell a coherent story. #### A reusable template saves the headache Building a §391.51 file from scratch every time a new driver comes on board is the single most common source of administrative violations during a compliance review. We package the same DQ file template our compliance team uses internally - fillable PDF plus editable Word - for $25 as a one-time, reusable purchase you can pair with any MVR order. The template covers every item above with the citations pre-filled and a reviewer signature block on each form, so you spend the onboarding meeting talking to the driver instead of rebuilding the paperwork. ### 49 CFR §391.23 vs §391.25: Pre-Hire MVR vs Annual Review Source: https://www.fastdriverscreening.com/guides/391-23-vs-391-25 Category: Compliance Published: 2026-04-15 Last Updated: 2026-06-12 Read time: 7 min The two FMCSA regulations that govern when a motor carrier must pull an MVR - pre-employment under §391.23 and annual review under §391.25. TL;DR: 49 CFR §391.23 sets the pre-employment investigation requirements (MVR from every state of license in the prior three years, CDLIS check, prior-employer inquiry); 49 CFR §391.25 sets the annual MVR + signed-review requirement. They are scored as independent violations on FMCSA audits. Key takeaways: - §391.23 governs everything before a driver's first dispatch: MVR from every state of license, CDLIS check for CDL holders, three-year employment investigation, road test. - §391.25 is recurring - annual MVR from every state of current licensure, signed written determination of qualification, retained in the §391.51 file. - The §391.23 thirty-day window starts on the driver's first day on the road, not the offer date. - The most common audit finding is a missing MVR from a prior state of residence - CDLIS surfaces every state where the driver held a CDL. - A cohort-based annual review schedule (everyone reviewed in the same calendar month) is easier to track than per-driver anniversary dates. Two FMCSA regulations govern when a motor carrier is required to pull a [Motor Vehicle Record](/glossary/mvr) on a commercial driver: [49 CFR §391.23](https://www.ecfr.gov/current/title-49/section-391.23), which sets the pre-employment investigation requirements, and [49 CFR §391.25](https://www.ecfr.gov/current/title-49/section-391.25), which sets the annual review requirement. They sound similar and they appear back-to-back in the regulations, but they cover different points in the driver's tenure with the carrier - and they are scored as independent violations on an FMCSA compliance review. A carrier can comply with one and miss the other, and rack up a penalty either way. This guide breaks down both regulations side by side: what each requires, when the requirement is triggered, what the carrier has to put in the DQ file, and the most common audit findings under each. #### §391.23 - Investigation and Inquiries (Pre-Employment) §391.23 governs everything that happens before a driver is placed on a commercial motor vehicle for the first time at your carrier. The regulation breaks the requirement into three tracks. ##### MVR for the prior three years > 49 CFR §391.23(a)(1) - Within 30 days of the date the driver's employment begins, the motor carrier shall make an inquiry to obtain the motor vehicle record of the driver from the appropriate agency of every State in which the driver held a commercial motor vehicle operator's license or permit during the preceding 3 years. A few practical points: - The thirty-day clock runs from the day the driver starts work - not from the day the offer letter goes out. - The inquiry covers every state where the driver held a license, not just the current issuing state. This is the most commonly missed step. A driver who moved from Texas to Oklahoma eighteen months ago needs MVRs from both states for the pre-employment file. - You file the actual returned record, dated and signed by the reviewer. ##### Three-year employment history > 49 CFR §391.23(a)(2) - Within 30 days of the date the driver's employment begins, the motor carrier shall make an investigation of the driver's employment record during the preceding 3 years. The §391.23(d) detail expands what the prior-employer investigation must cover: dates of employment, an inquiry into safety performance under DOT regulations, and (if the prior employer is DOT-regulated) the §40.25 drug-and-alcohol testing record. ##### CDL pre-employment requirement (CDLIS) > 49 CFR §391.23(m)(2) - For drivers required to have a commercial driver's license under part 383 of this chapter, using the CDLIS motor vehicle record obtained from the current licensing State, the motor carrier must verify and document in the driver qualification file the required driver information before allowing the driver to operate a CMV. [CDLIS](/glossary/cdlis) - the [AAMVA](/glossary/aamva)-operated system that tracks every CDL ever issued - is the only way to surface a CDL the driver may have held in a state they did not list on the application. A driver who held a CDL in Pennsylvania five years ago, lost it for a serious offense, then moved to Florida and obtained a new license could complete a Florida MVR with a clean record. The CDLIS check catches the Pennsylvania history. ##### What goes in the DQ file under §391.23 The pre-employment package, ready for the §391.51 file: - An MVR from every state where the driver held a license in the prior three years - A CDLIS check (CDL drivers only) - Documented investigation of the prior three years of employment - Drug-and-alcohol testing records from prior DOT-regulated employers - The signed driver's release authorizing all of the above #### §391.25 - Annual Inquiry and Review §391.25 picks up where §391.23 leaves off. Once the driver is on board, the carrier owes the driver - and the federal government - a yearly check on whether the driver is still qualified. The regulation has two distinct steps. ##### Step 1: Annual MVR inquiry > 49 CFR §391.25(a) - Except as provided in subpart G of this part, each motor carrier shall, at least once every 12 months, make an inquiry to obtain the motor vehicle record of each driver it employs, covering at least the preceding 12 months, to the appropriate agency of every State in which the driver held a commercial motor vehicle operator's license or permit during the time period. Practical points: - The clock is twelve months from the prior MVR - most carriers run all annual MVRs on a fixed calendar month for operational simplicity, which keeps you well inside the requirement. - "Every State in which the driver held a license" still applies. If a driver moved mid-year, the annual review must capture both states. ##### Step 2: Annual review of driving record > 49 CFR §391.25(b) - Except as provided in subpart G, each motor carrier shall, at least once every 12 months, review the motor vehicle record of each driver it employs to determine whether that driver meets minimum requirements for safe driving or is disqualified to drive a commercial motor vehicle. > 49 CFR §391.25(c) - The motor carrier shall consider any evidence that the driver has violated any applicable Federal Motor Carrier Safety Regulations and any evidence that the driver has violated any applicable State or local laws or regulations relating to traffic accidents. The review is a documented, written determination - not just a glance at the new MVR. The §391.25(d) requirement is explicit: the carrier files a note of the review's findings, signed and dated, in the DQ file. ##### What goes in the DQ file under §391.25 - A new MVR from every relevant state, dated within the prior twelve months - The driver's annual §391.27 list of violations - A signed annual review by the carrier, with a determination of qualification #### The most common audit findings under both Patterns that show up year after year in compliance reviews: - Pre-employment MVR pulled only from the current issuing state, not from every prior state - CDLIS check missing or older than the §391.23 thirty-day window - Annual review more than twelve months stale because the prior reviewer left and no one took over the calendar - Annual review documented but the underlying MVR was never refreshed - §391.27 violation self-certification missing because the carrier collected it once and never re-collected it Each one is a separate, scoreable violation on the audit report. None of them require complicated systems to avoid - only a documented calendar and a single source for both the pre-employment package and the yearly inquiry. #### How they pair together in practice A clean compliance posture treats §391.23 and §391.25 as the bookends of a driver's tenure. The §391.23 package is heavy: prior-three-years MVRs, prior-employer investigations, a CDLIS check, and a road-test certificate or equivalent. The §391.25 package is lean and recurring: a fresh MVR, the driver's certification, and the carrier's signed review. If you build the DQ file once with the §391.23 documents in their proper §391.51 order, then add a §391.25 package every year on a fixed calendar date, you have a file that audits cleanly even when the auditor pulls a driver who left the company eighteen months ago. | | §391.23 (Pre-Employment) | §391.25 (Annual Review) | | --- | --- | --- | | Regulation title | Investigation and Inquiries (Pre-Employment) | Annual Inquiry and Review | | When it applies | Before a driver is placed on a commercial motor vehicle for the first time | At least once every 12 months | | The package | Heavy: prior-three-years MVRs, prior-employer investigations, a CDLIS check, and a road-test certificate or equivalent | Lean and recurring: a fresh MVR, the driver's certification, and the carrier's signed review | #### A timeline view of a typical first year Imagine a driver whose first day on the road is March 1. Here is what the §391.23 / §391.25 calendar looks like for the first eighteen months of their employment: - February - Application for employment received. Driver signs the DPPA + FCRA consent. Pre-employment MVR pulled from every state of license in the prior three years. CDLIS query run for CDL drivers. - March 1 - First day on the road. The §391.23 thirty-day clock starts ticking; everything must be on file by March 30. - March 5 - Three-year employment investigation responses logged. §40.25 drug-and-alcohol records from prior DOT-regulated employers received. - March 10 - Road test certificate added (or §391.33 equivalent accepted). Medical examiner's certificate filed; National Registry verification under §391.23(m) printed. - December 31 - Driver signs the §391.27 annual list of violations. - February 28 (year two) - Annual MVR pulled from every state of current licensure. Annual review under §391.25(b) signed and added to the file. Carriers with more than a handful of drivers typically run the entire annual cohort on a single calendar month to avoid tracking individual anniversary dates. The §391.25 rule is "at least once every 12 months," so a fixed-month schedule satisfies the regulation as long as no driver's review slips past the twelve-month mark. #### Where audit findings come from The §391.23 / §391.25 audit trail is one of the easiest places to find violations during a New Entrant Safety Audit because it is entirely paper-based - the dates either match or they do not. The most common findings: - The pre-employment MVR is dated after the driver's first day on the road - The CDLIS check is missing for a CDL driver - The annual review for a long-tenured driver is more than twelve months stale - The annual review exists but the underlying MVR was never refreshed - The prior-employer investigation was never documented A clean file makes the rest of the audit move faster. An incomplete one slows everything else because the auditor has now flagged the carrier as someone whose paperwork can't be trusted. Pull both the pre-employment package and the annual MVR through FastDriverScreening. Same-day delivery - $40 MVR Basic, $60 [MVR + CDLIS](/guides/cdlis-vs-mvr), $100 DOT Pre-Employment (adds [PSP](/glossary/psp) and the [Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough)), and $60 Annual Refresh (MVR + Clearinghouse limited query for [§382.701(b)](https://www.ecfr.gov/current/title-49/section-382.701)) - with the issuing-state header that auditors expect to see. ### CDLIS vs MVR: Why a Single-State Record Is Not Enough Source: https://www.fastdriverscreening.com/guides/cdlis-vs-mvr Category: CDLIS Published: 2026-04-15 Last Updated: 2026-06-12 Read time: 7 min A Motor Vehicle Record only shows what one state knows. CDLIS is the federal database of every CDL ever issued. Here is what each report catches. TL;DR: A Motor Vehicle Record reflects one state's license history; CDLIS is the federal AAMVA index that surfaces every state where the driver has ever held a CDL. 49 CFR §391.23 requires both for a CDL pre-employment investigation - the MVR inquiry at §391.23(a)(1) and the CDLIS record check at §391.23(m)(2) - so the MVR + CDLIS bundle is the floor. Key takeaways: - An MVR shows everything the issuing-state DMV knows; CDLIS shows which states the driver has ever held a CDL or CDL learner's permit in. - A driver who lost a CDL in one state, surrendered it, and obtained a new license in another state can present a clean home-state MVR - only CDLIS surfaces the prior history. - §391.23(a)(1) requires an MVR from "every State in which the driver held a license" in the prior three years; CDLIS is how you know which states those are. - CDLIS is CDL-only - non-CDL commercial drivers do not have a CDLIS record, so the check returns nothing useful for them. - Both reports need DPPA + FCRA driver consent before they are pulled - the consent form must specifically authorize each report. If you only run a [Motor Vehicle Record](/glossary/mvr) on a CDL hire, you have done half the federally-required pre-employment screening. The other half is a [CDLIS](/glossary/cdlis) check - and it is the half most carriers skip the first time they hire a CDL driver. This is the single most common pre-employment violation we see in audit findings. The fix is the MVR + CDLIS package at $60 (versus $40 for MVR Basic), but you only know to choose it if you understand what each report does and what each one misses. #### The fundamental difference A Motor Vehicle Record is a state-level document. It is the issuing state DMV's official transcript of one driver's license history - every action, citation, and conviction the state knows about. It is comprehensive within the boundaries of that state and the period the state retains records (typically three to seven years for traffic offenses, longer for serious violations). What it does not contain is anything the issuing state never knew about: a license held in another state, a disqualification ordered by another state, a CDL the driver surrendered when they moved, or a conviction reported only to another jurisdiction. CDLIS - the Commercial Driver's License Information System - was built to fill exactly that gap. Operated by [AAMVA](/glossary/aamva) (American Association of Motor Vehicle Administrators), CDLIS is a federally-mandated pointer system that links every state DMV's CDL records together. It is not a single database of every driving offense; it is an index that, when queried with a driver's name, date of birth, and Social Security number (or other PII), returns every state where that driver has ever held a CDL or a CDL learner's permit, plus a summary of their current license status in each. #### What an MVR catches, and what it misses An MVR catches everything the issuing state DMV recorded - and only that. Specifically: - Current license status, class, and endorsements in the issuing state - Suspensions, revocations, and disqualifications imposed by the issuing state - Out-of-state convictions reported back to the issuing state under the Driver License Compact (which covers most ordinary violations but is not universal) - Accidents the issuing state DMV recorded - Medical certification status currently on file with the issuing state What an MVR routinely misses, even when the issuing state's record-keeping is excellent: - A CDL the driver previously held in another state and surrendered before applying for the current one - A disqualification entered by another state under §383.51 if it was not reported to the current state - A learner's permit pulled in a state the driver has since moved away from - Convictions in a non-Driver-License-Compact state (rare, but they exist) The gap is not theoretical. A driver who lost a CDL for DUI in Indiana, waited out the disqualification period, moved to Michigan, applied for a new CDL there, and listed only the Michigan address on the application can present a perfectly clean Michigan MVR. The Indiana history shows up on CDLIS. #### What CDLIS catches that an MVR cannot CDLIS surfaces: - Every state where the driver has ever held a CDL or CDL permit - Each state's current status (valid, suspended, disqualified, surrendered) - Cross-state disqualifications under §383.73 reciprocity - Active medical certification status on the federal level - A pointer to the state of record, which lets you pull the right MVRs for the §391.23 pre-employment file What CDLIS does not provide is the citation-level detail of an MVR. CDLIS will tell you the driver currently holds a Pennsylvania CDL with a recent suspension on file; the Pennsylvania MVR will tell you what the suspension was for and when it ends. The two reports are complementary, not interchangeable. The MVR tells you the story in one state; CDLIS tells you which states have a story to tell. | | MVR | CDLIS | | --- | --- | --- | | What it is | A state-level document | A federally-mandated pointer system that links every state DMV's CDL records together | | What it catches | Everything the issuing state DMV recorded - and only that | Every state where the driver has ever held a CDL or CDL permit | | What it tells you | The story in one state | Which states have a story to tell | | Pricing | $40 (MVR Basic) | $60 (MVR + CDLIS package) | #### When 49 CFR requires both The federal requirement to run both is in 49 CFR §391.23. Two clauses together create the obligation. > 49 CFR §391.23(a)(1) - Within 30 days of the date the driver's employment begins, the motor carrier shall make an inquiry to obtain the motor vehicle record of the driver from the appropriate agency of every State in which the driver held a commercial motor vehicle operator's license or permit during the preceding 3 years. The phrase "every State in which the driver held a license" is the operative one. To know which states those are, you have to query CDLIS - there is no other authoritative source. > 49 CFR §391.23(m)(2) - For drivers required to have a commercial driver's license under part 383 of this chapter, using the CDLIS motor vehicle record obtained from the current licensing State, the motor carrier must verify and document in the driver qualification file the required driver information before allowing the driver to operate a CMV. In practice, the FMCSA enforcement standard is straightforward: every CDL pre-employment investigation must include a CDLIS check, regardless of what the driver disclosed on the application. The CDLIS check tells you which state MVRs to pull; the MVRs tell you the underlying detail. #### When a CDLIS check is and is not required Required: - Every CDL pre-employment investigation under §391.23 - Every reasonable suspicion check that the driver may hold an undisclosed CDL in another state - Recommended any time the driver discloses a recent state-of-residence change Not required (but often run anyway, for the same gap reason): - Non-CDL commercial drivers (where §391.23 still requires an MVR but does not specifically mandate CDLIS) - Annual reviews under §391.25 where the driver has been with the carrier for several years and has not changed residency For a non-CDL driver, the cost-benefit case for a CDLIS check is weaker - most non-CDL commercial drivers genuinely do hold only their issuing-state license. For a CDL driver at hire, the case is open and shut: §391.23 requires it. #### DPPA, FCRA, and the consent layer Both MVR and CDLIS records are protected by the [Driver's Privacy Protection Act](/glossary/dppa) (18 USC §2721) and the [Fair Credit Reporting Act](/glossary/fcra) when used for employment screening. Before you run either, you need the driver's signed written consent acknowledging that you will pull their record. The consent language must specifically authorize the inquiry; a generic "background check" release is not sufficient under FCRA §1681b. See our [DPPA + FCRA consent guide](/guides/dppa-driver-consent) for sample language. FastDriverScreening builds the DPPA + FCRA-compliant consent attestation into checkout, so the file you receive includes the certification that you held the consent at the time of the pull. #### Pricing the bundle MVR Basic is $40; the MVR + CDLIS package is $60. The $20 difference covers the AAMVA query and the time it takes to cross-reference the result. For any CDL pre-employment screen, the MVR + CDLIS package is the minimum complete answer for §391.23 - and stepping up to DOT Pre-Employment at $100 adds the FMCSA PSP report and the Clearinghouse pre-employment query mandated under §382.701(a) before first dispatch. For any non-CDL hire, MVR Basic is sufficient. #### A worked example Take a hypothetical applicant: thirty-eight years old, currently licensed in Florida, with a clean Florida MVR going back three years. The application lists three years at one Florida-based carrier, no prior carriers, no prior states. Without CDLIS, you have a clean pre-employment file. Run CDLIS, and the report comes back showing the driver also held a Pennsylvania CDL that was disqualified four years ago after a DUI in a CMV - a §383.51(b) major offense triggering a one-year disqualification. The Pennsylvania disqualification has long since ended, the driver legally surrendered the Pennsylvania license before applying in Florida, and Florida had no obligation to mirror the disqualification onto the new state license. The disqualification is over and the driver is currently legally licensed. But the driver did not list Pennsylvania on the application. That is now a §391.21 disclosure issue separate from the underlying offense - and it changes the pre-employment determination. Without CDLIS, you would have hired the driver. With CDLIS, you have all the information needed to make the call. The example illustrates the broader pattern: CDLIS does not change every pre-employment decision, but it changes enough of them, on hires that would otherwise have looked clean, that the cost is trivial against the risk. #### What CDLIS does NOT do A few clarifications worth flagging because we hear them from new carriers: - CDLIS is not a criminal background check. Use a separate criminal-history vendor for that. - CDLIS does not show traffic citations in real time - it only reflects what each state DMV has reported up the chain. - CDLIS does not automatically pull the underlying state MVR. You still order the MVR separately for each surfaced state. - CDLIS cannot be queried without driver consent. The same DPPA + FCRA consent that authorizes the MVR pull also authorizes the CDLIS query. #### When the audit comes FMCSA's New Entrant Safety Audit comes for every new carrier within the first eighteen months of operation. The auditor will check the §391.23 file for the MVRs and the CDLIS check on every CDL driver. Make sure both are there. ### DPPA & FCRA Driver Consent: What the Law Requires Source: https://www.fastdriverscreening.com/guides/dppa-driver-consent Category: Compliance Published: 2026-04-15 Last Updated: 2026-05-01 Read time: 8 min The Driver's Privacy Protection Act (18 USC §2721) and the Fair Credit Reporting Act both require written driver consent before an MVR pull. Sample language inside. TL;DR: Pulling an MVR or CDLIS check without the driver's signed written consent is a federal violation under the DPPA (18 USC §2721) and the FCRA (15 USC §1681b). Get the consent form right once and you can reuse it on every driver - sample language included. Key takeaways: - DPPA §2721(b)(9) lets carriers pull an MVR on a CDL holder for §391.23/§391.25 purposes; §2721(b)(2) covers non-CDL commercial drivers. - FCRA §1681b(b)(2) requires a stand-alone, clear-and-conspicuous written disclosure plus written authorization before pulling a "consumer report" for employment. - A single consent document drafted to satisfy both statutes is the practical solution; it must be stand-alone (not buried in the application) and signed by the driver. - DPPA §2724 penalties start at $2,500 per violation; FCRA §1681n adds $100–$1,000 per willful violation plus actual damages and attorney's fees. - Retain the signed consent in the §391.51 file for the duration of employment plus three years. Pulling a [Motor Vehicle Record](/glossary/mvr) on a commercial driver without first obtaining the driver's signed written consent is a federal civil violation. The consent requirement comes from two overlapping laws that govern, separately, the DMV record itself and its use for employment screening: the [Driver's Privacy Protection Act (DPPA)](/glossary/dppa) at 18 USC §§2721–2725, and the [Fair Credit Reporting Act (FCRA)](/glossary/fcra) at 15 USC §1681. Each law has independent requirements, each carries independent penalties, and each is enforceable in private civil litigation by the driver whose record was pulled. The fix is straightforward: a clean, dated, signed consent on file before the pull. Get the form right once and you can reuse it on every driver. This guide explains what each law requires, where the requirements overlap and where they diverge, and shows what compliant consent language looks like. Use it as a reference when you build your DQ file template. #### The Driver's Privacy Protection Act (DPPA) The DPPA is the federal law that governs DMV records as a category. It was enacted in 1994 and has been amended several times since. > 18 USC §2721(a) - A State department of motor vehicles, and any officer, employee, or contractor thereof, shall not knowingly disclose or otherwise make available to any person or entity personal information, as defined in 18 USC §2725(3), about any individual obtained by the department in connection with a motor vehicle record, except as provided in subsection (b) of this section. The general rule: DMV records are private, and the state cannot release them, period. The exceptions in §2721(b) are what allow employer screening: > 18 USC §2721(b)(2) - For use in connection with matters of motor vehicle or driver safety and theft; motor vehicle emissions; motor vehicle product alterations, recalls, or advisories; performance monitoring of motor vehicles, motor vehicle parts and dealers; motor vehicle market research activities, including survey research; and removal of non-owner records from the original owner records of motor vehicle manufacturers. > 18 USC §2721(b)(9) - For use by an employer or its agent or insurer to obtain or verify information relating to a holder of a commercial driver's license that is required under chapter 313 of title 49. The §2721(b)(9) exception is the one that authorizes carriers to pull an MVR on a CDL holder for §391.23/§391.25 purposes. For non-CDL drivers, motor carriers typically rely on §2721(b)(2) (driver safety) or §2721(b)(1) (use by a government agency). Across both clauses, the practical compliance posture is the same: you must have a permissible purpose, and the standard way to document it is the driver's written, signed consent. > 18 USC §2721(b)(13) - For any other use specifically authorized under the law of the State that holds the record, if such use is related to the operation of a motor vehicle or public safety. > 18 USC §2724 - A person who knowingly obtains, discloses, or uses personal information from a motor vehicle record, for a purpose not permitted under this chapter, shall be liable to the individual to whom the information pertains. Penalties under §2724 include actual damages of not less than $2,500 per violation, attorney's fees, and punitive damages. Statutory liability accrues per record - pulling fifty MVRs without consent is fifty separate violations. #### The Fair Credit Reporting Act (FCRA) The FCRA layers on top of the DPPA whenever the MVR is used for employment screening. It treats the record (and the company that pulled it) as a "consumer report" and "consumer reporting agency" respectively, and imposes a separate disclosure-and-consent regime. > 15 USC §1681b(b)(2) - A consumer reporting agency may furnish a consumer report for employment purposes only if (A) the person who obtains the report from the agency certifies to the agency that (i) the person has complied with paragraph (3) [the disclosure-and-authorization rule] and that the information contained in the report will not be used in violation of any applicable Federal or State equal employment opportunity law or regulation. > 15 USC §1681b(b)(2)(A) - A person may not procure a consumer report, or cause a consumer report to be procured, for employment purposes with respect to any consumer, unless (i) a clear and conspicuous disclosure has been made in writing to the consumer at any time before the report is procured or caused to be procured, in a document that consists solely of the disclosure, that a consumer report may be obtained for employment purposes; and (ii) the consumer has authorized in writing the procurement of the report by that person. The key FCRA points: - The disclosure must be a "stand-alone" document - it cannot be buried in the employment application or a general waiver. - The disclosure must be "clear and conspicuous." - The driver's authorization must be in writing. - If you intend to take adverse action based on what the report shows (the §391.15 disqualification analysis), you must follow the §1681b(b)(3) pre-adverse-action process: provide the driver with a copy of the report and a summary of FCRA rights before making the final decision. FCRA penalties for negligent or willful violations sit at $100 to $1,000 per violation under §1681n, plus attorney's fees and punitive damages. #### Where DPPA and FCRA overlap For a motor carrier pulling an MVR on a hire, both laws apply simultaneously: - DPPA tells the DMV they may release the record (because there is a permissible purpose and consent on file). - FCRA tells the carrier they may use the record (because they made the stand-alone disclosure and obtained written authorization). A single consent document, drafted to satisfy both, is the practical solution. The disclosure must be stand-alone for FCRA, must specifically authorize the MVR pull for DPPA, and must include the driver's signature and date. #### Sample consent language Below is a compliant template. It is not legal advice and you should have your own counsel review the language for your specific jurisdiction, but it covers every element required by both DPPA and FCRA. ``` DRIVER AUTHORIZATION TO RELEASE MOTOR VEHICLE RECORD I, [DRIVER FULL LEGAL NAME], holding driver's license number [LICENSE NUMBER] issued by the State of [ISSUING STATE], hereby: (1) ACKNOWLEDGE that [CARRIER NAME] ("the Company") has informed me, in this stand-alone document, that a consumer report, including a Motor Vehicle Record (MVR) and, where applicable, a Commercial Driver's License Information System (CDLIS) report, may be obtained for employment purposes from the issuing-state Department of Motor Vehicles and from AAMVA; (2) AUTHORIZE the Company, and any consumer reporting agency acting on its behalf, to obtain such reports for the purpose of evaluating my qualifications for employment as a commercial motor vehicle driver, including any subsequent annual reviews required by 49 CFR §391.25; (3) UNDERSTAND that this authorization is given pursuant to the Driver's Privacy Protection Act (18 USC §2721(b)(9)) and the Fair Credit Reporting Act (15 USC §1681b(b)(2)) and that the report obtained under this authorization will be used only for the purposes stated above; (4) CERTIFY that all information I have provided in connection with my application for employment is true and complete to the best of my knowledge. ___________________________________ Driver signature ___________________________________ Date ___________________________________ Print name ``` A few drafting notes: - The disclosure paragraph (item 1) is what makes the document "stand-alone" under FCRA §1681b(b)(2)(A)(i). Do not stack this onto the bottom of the application. - The authorization paragraph (item 2) covers both the initial pre-employment check and the annual §391.25 reviews, which means you do not need to re-collect consent every year. - The DPPA citation (item 3) lets the DMV match the request against the §2721(b)(9) permissible-purpose exception. #### Retention and re-consent Keep the signed consent in the [DQ file under §391.51](/guides/dq-file-checklist) for the entire period the driver is employed plus three years. If a driver materially changes role, asks to revoke consent, or is terminated and rehired, collect a fresh consent under the same template. #### Where FastDriverScreening fits in Our checkout flow includes the DPPA + FCRA-compliant attestation built into the order - when you submit, the order receipt records that you held the driver's consent at the time of the pull. You can attach your own signed driver consent to the file, or use the stand-alone template our DQ File package includes. Either way, the consent layer is solved before the pull happens, which is exactly where the DPPA and FCRA both want it. ### MVR Comes Back With a Violation: A Decision Tree Source: https://www.fastdriverscreening.com/guides/mvr-violations-decision-tree Category: Compliance Published: 2026-04-15 Last Updated: 2026-05-01 Read time: 8 min A step-by-step framework for evaluating violations on a Motor Vehicle Record against the FMCSA disqualification criteria in 49 CFR §391.15 and §383.51. TL;DR: When an MVR shows a violation, classify it under §383.51(b) major offenses or §383.51(c) serious traffic violations, check the lookback window, verify license status under §391.15, and document a written determination in the §391.51 file. Key takeaways: - A current SUSPENDED, REVOKED, CANCELLED, or DISQUALIFIED status on the MVR triggers an automatic §391.15 stop - the driver cannot operate a CMV. - §383.51(b) major offenses (DUI, refusal, leaving the scene, CMV felony, etc.) trigger one-year disqualifications on first conviction; lifetime ban on second. - §383.51(c) serious traffic violations (15+ over, reckless, hand-held phone, texting, following too closely) require a count: two within three years = 60-day disqualification. - Pending charges and dismissed convictions are not disqualifying - but the carrier still owes a written file note explaining the analysis. - The §391.51 file must contain a signed determination ("driver remains qualified" or "disqualified under §[cite] until [date]") for every annual review. An [MVR](/glossary/mvr) comes back with a violation on it. What do you do? The answer is not "no, thank you" - most commercial drivers have something on their record, and the federal disqualification rules are narrower than most carriers assume. The answer is also not "ignore it." It is a structured, documented review against the specific FMCSA disqualification criteria, with a written determination filed in the DQ file. The decision tree below walks through that review for every common violation type. The criteria you are checking against come from three regulations: > 49 CFR §391.15 - General disqualification rules. A driver is disqualified while their CDL is suspended, revoked, or cancelled by any state; while the driver's privilege to drive is suspended in any state; while the driver does not have a current medical certificate; or while the driver has been convicted of certain felony offenses involving the use of a CMV. > 49 CFR §383.51(b) - Major offenses. DUI/DWI, refusing a chemical test, leaving the scene of an accident, using a CMV in the commission of a felony, driving while disqualified, and causing a fatality through negligent operation. First conviction triggers a one-year disqualification (three years if HazMat); second triggers a lifetime ban. > 49 CFR §383.51(c) - Serious traffic violations. Excessive speeding (15+ mph over), reckless driving, improper lane change, following too closely, texting while driving, and using a hand-held phone while driving a CMV. Two within three years triggers a 60-day disqualification; three triggers 120 days. Use the decision tree below in order. Each branch ends with the documented action you take and the file note you write. #### Step 1: Confirm the violation actually exists Before anything else, verify the violation is real and current. MVRs occasionally show pending charges, dismissed convictions, or stale entries from prior states. Check: - Is the line on the report a conviction or a pending charge? Pending charges do not trigger disqualification under §383.51 - but they may be material to your hiring decision under your own policies. - Is the conviction date within the §383.51 lookback window (usually three years for serious traffic violations, ten years for some major offenses)? - Was the charge eventually dismissed, reduced, or sealed? An MVR sometimes shows the original charge even after a dismissal - pull the court record if you are unsure. If the violation is not a conviction, is outside the lookback window, or has been dismissed, write a note to file and proceed with the hire. Document the specific check you ran - auditors will ask. #### Step 2: Check current license status The single most important question on any MVR is the current license-status field. If the line says SUSPENDED, REVOKED, CANCELLED, or DISQUALIFIED, you have an automatic stop: > 49 CFR §391.15(a) - A driver is disqualified to drive a commercial motor vehicle while the driver's commercial driver's license, commercial learner's permit, or non-CDL is suspended, revoked, or canceled by any State, or while the driver's privilege to drive a commercial motor vehicle is suspended, revoked, or canceled by any State, Canadian Province, or country. In this case, the driver cannot operate a CMV regardless of what other lines on the MVR show. Document the file with the status code, the underlying reason, and the projected reinstatement date. Re-pull the MVR after reinstatement and re-evaluate. If the license status is VALID, continue to step 3. #### Step 3: Classify the violation under §383.51 For each conviction line on the MVR, classify it as: - A major offense under §383.51(b) - DUI, refusal, leaving the scene, CMV felony, driving while disqualified, negligent fatality - A serious traffic violation under §383.51(c) - speeding 15+ over, reckless driving, improper lane change, following too closely, texting while driving a CMV, hand-held phone while driving a CMV - A railroad-highway grade-crossing offense under §383.51(d) - A non-disqualifying violation - anything that does not fall in the categories above (most ordinary moving violations) The classification determines your timeline and your documentation. ##### Major offense (§383.51(b)) A first conviction triggers a one-year disqualification (three years if the violation occurred in a placarded HazMat vehicle). A second triggers a lifetime ban (with limited reinstatement under §383.51(b)(2)). If the MVR shows a major offense within the lookback period and the disqualification is still active, the driver is disqualified - refer back to step 2 and write the file note. If the disqualification period has ended and the driver's license is currently valid, the conviction is a hiring-decision factor under your own policies but does not automatically bar the hire under §391.15. Document the conviction, the disposition, the disqualification period and its end date, and the specific finding that the driver is currently qualified. ##### Serious traffic violation (§383.51(c)) A single conviction is not disqualifying on its own. The disqualification triggers when two or more occur within three years (60-day disqualification) or three or more occur within three years (120-day disqualification). Count the convictions in the three-year window. If the count puts the driver in or above a disqualification threshold and the disqualification period has not ended, the driver is disqualified. If the count is below the threshold or the disqualification period has ended, document the analysis and proceed. ##### Railroad-highway grade-crossing offenses (§383.51(d)) A single conviction is a 60-day disqualification; a second within three years is a 120-day disqualification; a third within three years is a one-year disqualification. Same analytical framework as §383.51(c). ##### Non-disqualifying violations Ordinary moving violations - minor speeding, failure-to-yield, equipment violations - do not trigger §383.51 disqualification. They do, however, factor into your annual review under §391.25(c) and any pattern of safety violations is itself a flag. Document each conviction in the DQ file and reassess at annual review. #### Step 4: Check the medical certification Even if every conviction passes review, an expired or downgraded medical card disqualifies the driver under §391.41. Verify the medical examiner's certificate is current and that the medical examiner appears on the National Registry per §391.23(m). If the cert is expired, the driver cannot operate the CMV until a new exam is on file. #### Step 5: Document the determination The §391.51(b)(8) DQ file requires a written, signed annual review determining whether the driver remains qualified. The same documentation discipline applies to your initial pre-employment evaluation. The file note should include: - The specific violations identified on the MVR (date, offense, statute) - The classification under §383.51 (major, serious, grade-crossing, non-disqualifying) - The lookback analysis (how many convictions in what window) - Any current disqualification and its end date - The medical certification check - A signed conclusion: either "the driver is qualified to operate a CMV under 49 CFR Part 391" or "the driver is disqualified under §[specific cite] until [date]" - The reviewer's signature and date This file note is the document an FMCSA auditor reads to verify you did the §391.25 review correctly. A clean note is the difference between a "no violations" finding and a §391.25 violation on the audit report. #### Special cases worth flagging A few patterns that come up often enough to deserve their own handling: - Out-of-state convictions reported under the Driver License Compact: treat them under the issuing-state's classification, not the state where the offense occurred. The reciprocity rule in §383.73 makes the conviction count as if it occurred in the state of record. - Convictions in a CMV vs. a personal vehicle: many §383.51 violations apply only when the driver was operating a CMV at the time. Read the conviction line carefully - the MVR usually flags CMV offenses. - Withdrawal of a CDL for non-safety reasons: child support, unpaid fines, and similar withdrawals still disqualify the driver under §391.15(a) until the underlying issue is resolved. #### When in doubt, document anyway The most expensive audit findings come from violations that were not actually disqualifying but had no contemporaneous file note to prove the carrier did the review. The cost of writing a paragraph to file is zero; the cost of an audit violation is six months of CSA score impact. Treat every conviction on every MVR as something worth twenty seconds of documented analysis, file the result with the MVR in the §391.51 folder, and the audit takes care of itself. When you need a fresh MVR to start the analysis, FastDriverScreening delivers the issuing-state record with same-day turnaround and the optional [CDLIS](/glossary/cdlis) check that surfaces convictions in states the driver did not list on the application. ### Non-CDL vs CDL Driver Screening: What's Actually Different Source: https://www.fastdriverscreening.com/guides/non-cdl-vs-cdl-driver-screening Category: Hiring Published: 2026-04-15 Last Updated: 2026-06-12 Read time: 7 min When non-CDL commercial drivers need an MVR (almost always) and when they need CDLIS (almost never). What changes about §391 once the CDL line is crossed. TL;DR: FMCSA pre-employment screening rules apply to every CMV driver - CDL or non-CDL. Both need MVRs, prior-employer investigations, road tests, medical certificates, and annual reviews. CDL drivers add CDLIS, FMCSA Clearinghouse queries, and §382 drug-and-alcohol testing. Key takeaways: - A vehicle is a CMV at 10,001+ lbs GVWR, 8+ passengers for compensation (or 15+ not for compensation), or any placardable HazMat - much broader than CDL thresholds. - Both CDL and non-CDL screening require: §391.21 application, §391.23 pre-employment MVR (every state of license), §391.31 road test, §391.43 medical certificate, §391.25 annual review. - CDL-only requirements: CDLIS check (§391.23(m)(2)), §382.701 Clearinghouse pre-employment query, §40.25 prior-employer drug-and-alcohol records, §382 random testing pool. - A driver who currently holds a CDL but is hired for a non-CDL position must still get the full CDL screening package. - Both kinds of files retain for the duration of employment plus three years under §391.51(d). A common assumption among new motor carriers is that the [FMCSA](https://www.fmcsa.dot.gov) pre-employment screening rules only apply to CDL drivers. That is wrong, and the misunderstanding is one of the most expensive mistakes you can make in your first year of operation. The pre-employment requirements in 49 CFR §391.23, the annual review requirement in §391.25, and the entire DQ file regime under §391.51 apply to every driver of a Commercial Motor Vehicle (CMV) - CDL or not. The CDL-specific requirements are layered on top, but the base requirements apply across the board. This guide walks through what is actually different between a CDL and non-CDL screening, where the regulations converge, and what your DQ file should look like for each. #### What makes a driver "commercial" under FMCSA Before anything else, define the universe of drivers you need to screen. The federal definition of CMV (49 CFR §390.5) is broader than most carriers expect. A vehicle is a CMV if it: - Has a gross vehicle weight rating (GVWR) of 10,001 lbs or more (most box trucks, larger pickups with trailers, etc.); or - Is designed to transport more than 8 passengers (including the driver) for compensation, or more than 15 not for compensation; or - Transports hazardous materials in placardable quantities A driver who operates any of those vehicles in interstate commerce is subject to Part 391, regardless of whether the vehicle requires a CDL. The CDL line is at GVWR 26,001 lbs or 16+ passengers (including the driver) or any HazMat in placardable quantities - drivers below those thresholds are non-CDL commercial drivers, not exempt drivers. #### Where the rules are identical For both CDL and non-CDL drivers, you owe the federal government: - A complete employment application under §391.21 - A pre-employment MVR from every state where the driver held a license in the prior three years, under §391.23(a)(1) - An investigation of the driver's prior three years of employment, under §391.23(a)(2) - A road test certificate or its equivalent under §391.31/§391.33 - A current medical examiner's certificate from a National Registry examiner under §391.43 - An annual MVR and signed review under §391.25 - A driver's annual list of violations under §391.27 - A complete DQ file under §391.51, retained for the duration of employment plus three years Every one of those requirements applies to a non-CDL commercial driver exactly as it applies to a CDL driver. The MVR you pull on a Class C non-CDL driver of a 12,000 lb box truck has the same regulatory weight as the MVR you pull on a Class A tractor-trailer driver. #### Where the rules diverge The differences between CDL and non-CDL screening are concentrated in three places: CDLIS, drug-and-alcohol testing, and disqualification analysis. ##### CDLIS [CDLIS](/glossary/cdlis) - the Commercial Driver's License Information System - is a CDL-only database. By definition, a non-CDL driver has no CDLIS record. Pulling a CDLIS check on a non-CDL driver returns nothing useful, and the FMCSA pre-employment requirement under [§391.23](/guides/391-23-vs-391-25) specifically references CDLIS only for CDL holders. See our [CDLIS vs MVR comparison](/guides/cdlis-vs-mvr) for the full scope of each report. > 49 CFR §391.23(m)(2) - For drivers required to have a commercial driver's license under part 383 of this chapter, using the CDLIS motor vehicle record obtained from the current licensing State, the motor carrier must verify and document in the driver qualification file the required driver information before allowing the driver to operate a CMV. For non-CDL drivers, the §391.23 MVR requirement still applies - you pull the issuing-state MVR. You just do not add the CDLIS query. A practical exception: if a non-CDL driver lists a recent state-of-residence change on their application, or if any other red flag suggests they might have held a CDL elsewhere, run a CDLIS check anyway. The cost is a $10 add-on and the gap-closing value is high. ##### Drug-and-alcohol testing Drug-and-alcohol testing under 49 CFR Part 382 applies only to CDL drivers. A non-CDL commercial driver is not subject to the §382 random testing pool, the §382.301 pre-employment testing requirement, or the §40.25 prior-employer drug-testing record query. This is the most consequential difference between the two screening regimes. A CDL pre-employment package is heavy with §40.25 prior-employer drug testing records; a non-CDL package is not. That said, many carriers run drug-and-alcohol testing on non-CDL drivers as a matter of policy, both for insurance reasons and for consistency in operations. If you do, the testing is a company policy rather than a federal requirement, and you can structure it on your own terms. ##### Disqualification analysis The §383.51 disqualification rules apply only to CDL drivers. A non-CDL commercial driver is not subject to the one-year DUI disqualification, the two-strikes serious-violation rule, or any of the other §383.51 categories. > 49 CFR §383.51 - Applicability: this section applies to a person required to have a commercial driver's license. That does not mean a DUI on a non-CDL driver's MVR is irrelevant - far from it. It is a §391.25(c) factor in the annual review, a §391.27 self-certification trigger, a §391.15 issue if it suspended the underlying license, and a hiring-decision factor under your own carrier policies. But the federal mandatory-disqualification mechanism only applies to CDL drivers. The practical implication is that the non-CDL annual review under §391.25 is more of a judgment call than a checklist. The MVR comes back, you read it against §391.15 (license-status disqualification still applies) and your own policies, and you write a signed determination. #### Building the DQ file for each For a CDL driver, the [§391.51 file](/guides/dq-file-checklist) looks like: - Application for employment (§391.21) - MVRs from every state in the prior three years (§391.23(a)(1)) - CDLIS check (§391.23(m)(2) for CDL) - Three-year employment investigation (§391.23(a)(2)/(d)) - §40.25 drug-and-alcohol testing records from prior DOT-regulated employers - Road test certificate or equivalent (§391.31/§391.33) - Medical examiner's certificate (§391.43) plus National Registry verification (§391.23(m)) - Annual §391.25 review and §391.27 self-certification (built up over time) - Driver consent under [DPPA + FCRA](/guides/dppa-driver-consent) For a non-CDL commercial driver, the file looks like: - Application for employment (§391.21) - MVRs from every state in the prior three years (§391.23(a)(1)) - Three-year employment investigation (§391.23(a)(2)/(d)) - Road test certificate or equivalent (§391.31/§391.33) - Medical examiner's certificate (§391.43) plus National Registry verification (§391.23(m)) - Annual §391.25 review and §391.27 self-certification - Driver consent under DPPA + FCRA The non-CDL file is the same as the CDL file minus the CDLIS check and the §40.25 drug-and-alcohol records. Everything else carries over identically. | CDL driver (§391.51 file) | Non-CDL commercial driver file | | --- | --- | | Application for employment (§391.21) | Application for employment (§391.21) | | MVRs from every state in the prior three years (§391.23(a)(1)) | MVRs from every state in the prior three years (§391.23(a)(1)) | | CDLIS check (§391.23(m)(2) for CDL) | | | Three-year employment investigation (§391.23(a)(2)/(d)) | Three-year employment investigation (§391.23(a)(2)/(d)) | | §40.25 drug-and-alcohol testing records from prior DOT-regulated employers | | | Road test certificate or equivalent (§391.31/§391.33) | Road test certificate or equivalent (§391.31/§391.33) | | Medical examiner's certificate (§391.43) plus National Registry verification (§391.23(m)) | Medical examiner's certificate (§391.43) plus National Registry verification (§391.23(m)) | | Annual §391.25 review and §391.27 self-certification (built up over time) | Annual §391.25 review and §391.27 self-certification | | Driver consent under DPPA + FCRA | Driver consent under DPPA + FCRA | #### What this means for screening costs The pricing implication is simple. For a CDL hire, the floor is the $60 [MVR + CDLIS](/guides/cdlis-vs-mvr) package; the $100 DOT Pre-Employment package is the right call when you need the [§382.701(a) Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough) (mandatory before first dispatch) plus [FMCSA PSP](/glossary/psp) in the same transaction. For a non-CDL commercial hire, the right pull is MVR Basic at $40 alone - unless the driver discloses a recent state-of-residence change, in which case stepping up to MVR + CDLIS is the safer move. Either way, you are not exempt from §391.23 just because the driver does not need a CDL. The DQ file applies, the MVR applies, the medical card applies, the road test applies, and the annual review applies. The only piece that does not apply is the CDLIS check and the §382 drug-testing program. #### Edge cases worth flagging A few patterns that come up often enough to deserve their own handling: - A driver who currently holds a CDL but is being hired for a non-CDL position. Treat the screen as a CDL screen - the driver is a CDL holder, and §391.23(m)(2) requires the CDLIS check for any CDL pre-employment investigation regardless of the position they are being hired into. - A driver who held a CDL in a prior period but voluntarily surrendered it. The current application is a non-CDL hire under §391.23, but the prior CDL history is still material under §391.21 disclosure. Run the CDLIS query as a precaution. - Intrastate-only operations in some states. A handful of states have adopted intrastate-only rules that exempt purely intrastate operations from the federal Part 391 requirements; check your state's specific rules. The federal floor still applies to every interstate motor carrier. - HazMat drivers below the CDL weight threshold. A non-CDL driver hauling placardable HazMat is technically subject to additional §172 / §177 hazardous-materials requirements regardless of vehicle class. The MVR + DQ file framework still applies - and the CDL classification is triggered by the placard, not the weight. #### What this does NOT change It is worth being explicit about the things the CDL / non-CDL distinction does not change: - The §391.51 retention rule - three years past separation - applies to both kinds of files. - The DPPA consent requirement under 18 USC §2721(b)(9) for CDL holders and §2721(b)(2) / (b)(13) for non-CDL drivers. Either way, you need the driver's signed consent before pulling the MVR. - The FCRA disclosure-and-authorization rule under 15 USC §1681b(b)(2). FCRA does not distinguish between CDL and non-CDL screening; it only requires that you make the stand-alone disclosure and obtain written authorization before pulling the report for employment purposes. #### The bottom line Both file types need the same backbone - application, MVRs, employment investigation, road test, medical card, annual review - and both files apply if you operate a CMV in interstate commerce. The CDL package adds the CDLIS check and the §382 drug-and-alcohol program; the non-CDL package skips both. Everything else carries over. When the New Entrant Safety Audit comes - and it comes for every new motor carrier within the first eighteen months - the auditor will pull the DQ file on every driver, CDL or not. Make sure both kinds of files are complete. ### How to Handle a Failed Pre-Employment Screening Source: https://www.fastdriverscreening.com/guides/how-to-handle-a-failed-pre-employment-screening Category: Hiring Published: 2026-04-15 Last Updated: 2026-05-01 Read time: 7 min When a pre-employment PSP, MVR, or CDLIS report comes back with disqualifying content - the FCRA adverse-action sequence and the §391.15 §383.51 line. TL;DR: When a pre-employment PSP, MVR, or CDLIS report shows a problem, follow the FCRA pre-adverse-action process: classify the issue, send the report and Summary of Rights to the driver, wait the dispute window, then take final adverse action with the §1681m notice. Document everything in the file. Key takeaways: - A current §391.15 disqualification (suspended/revoked license, no medical card) is an automatic stop - no procedural FCRA waiting period changes that. - If the issue is discretionary, FCRA §1681b(b)(3) requires you to send the report and the Summary of Your Rights before declining the hire. - Five business days is the FTC's informal minimum dispute window; if the driver disputes, the consumer reporting agency has 30 days under §1681i. - The final adverse-action letter must name the screening agency, note that the agency did not make the decision, and tell the driver they have 60 days to request a free copy. - Document the entire process - original report, classification, pre-adverse package, response, final letter - and retain alongside the §391.51 file. A pre-employment screening report comes back, and there is a problem. Maybe it is a recent DUI on the [MVR](/glossary/mvr), a multi-state CDL on the [CDLIS](/glossary/cdlis) check that the driver did not disclose, or a string of preventable accidents on the [FMCSA Pre-Employment Screening Program (PSP)](/glossary/psp) report. Now what? The answer is a structured, FCRA-compliant process - not a phone call telling the driver they did not get the job. Skipping the procedural steps is the single most common source of FCRA litigation against motor carriers, and the statutory damages are substantial. This guide walks through the process from "the report came back bad" to "the file is closed and the documentation is complete." Use it any time a pre-employment report shows a potential disqualifier. #### Step 1: Read the report carefully Before you do anything else, make sure you actually understand what the report shows. The most common false alarms: - An MVR shows what looks like a DUI but is actually a reduced-charge wet-reckless or careless-driving conviction - A PSP report shows a serious crash but the driver was not at fault (the PSP report is not adjudicated - it includes accidents regardless of fault) - A CDLIS check shows a CDL in another state that the driver disclosed but in different words on the application - A status code is unfamiliar but not actually a disqualification If after a careful read the report still shows a problem, proceed to step 2. #### Step 2: Classify the issue under federal rules The federal disqualification framework determines whether the driver is automatically barred or whether the decision is at your discretion. The categories are: - Currently disqualified under [§391.15](https://www.ecfr.gov/current/title-49/section-391.15): license suspended, revoked, cancelled, or under §383.51 disqualification, or no current medical card. The driver cannot legally operate a CMV. - Currently within a [§383.51](https://www.ecfr.gov/current/title-49/section-383.51) disqualification period: a major offense or accumulated serious violations within the lookback window. See our [MVR violations decision tree](/guides/mvr-violations-decision-tree) for the classification analysis. - A pattern that fails your own policies but passes the federal floor: e.g., three minor moving violations in two years on a non-CDL driver. Federal rules do not bar the hire, but your policies might. - An undisclosed item the driver should have disclosed: e.g., a CDL in another state surfaced by CDLIS that the driver did not list on the §391.21 application. This is a §391.21 disclosure failure, separate from any underlying offense. The category determines the next step. If the driver is currently disqualified under federal rules, you cannot hire them regardless of any procedural compliance - the job offer cannot be extended at all. If the issue is a discretionary call, you must follow the FCRA pre-adverse-action process before declining the hire. #### Step 3: Follow the FCRA pre-adverse-action process This step is the legal core of the procedure. The Fair Credit Reporting Act treats the screening report as a "consumer report" and requires a specific sequence before you take "adverse action" (declining the hire or any other negative employment decision based on the report). > 15 USC §1681b(b)(3)(A) - Before taking any adverse action based in whole or in part on a consumer report, the person intending to take such adverse action shall provide to the consumer to whom the report relates: (i) a copy of the report; and (ii) a description in writing of the rights of the consumer under this subchapter, as prescribed by the Bureau under section 1681g(c)(3) of this title. In practice, the pre-adverse-action package includes: - A copy of the consumer report (the MVR, CDLIS, or PSP report) - The CFPB's "Summary of Your Rights Under the Fair Credit Reporting Act" (the form is available on the CFPB website and must be the current version) - A short cover letter explaining that you are considering an adverse hiring decision based on the report and that the driver has a reasonable period (the FTC informally suggests five business days) to dispute its accuracy or completeness Send the package to the driver at the address on the application. Do not take the final adverse action yet - you are giving the driver the chance to dispute the report. #### Step 4: Wait for the dispute window The federal rule does not specify the exact length of the waiting period, but the FTC's interpretive guidance (and most FCRA case law) treats five business days as a reasonable minimum. During the wait: - If the driver disputes the report, the dispute typically goes to the consumer reporting agency under §1681i, which has thirty days to investigate. You may pause the hiring decision while the investigation runs. - If the driver provides a substantive response (a court document showing the conviction was dismissed, a corrected MVR pulled by the driver themselves), you reassess the report against the response. - If the driver does not respond within the waiting period, you proceed to step 5. #### Step 5: Take the final adverse action After the waiting period (or after the dispute is resolved without changing the substance of the report), if you still intend to decline the hire, you take the formal adverse action. > 15 USC §1681b(b)(3) and §1681m(a) - When adverse action is taken, the person taking the action must provide notice to the consumer including: the name, address, and telephone number of the consumer reporting agency that supplied the report; a statement that the agency did not make the decision and is unable to provide specific reasons; and notice of the consumer's right to obtain a free copy of the report from the agency within 60 days and to dispute the report's accuracy or completeness. Send the adverse-action letter to the driver. The letter should: - State the decision (e.g., "we are unable to extend an offer of employment") - Identify the consumer reporting agency (your screening provider - for an MVR pulled through FastDriverScreening, that is FastDriverScreening with our address and phone number) - Note that the screening agency did not make the hiring decision - Note the driver's right to a free copy of the report and the right to dispute its accuracy #### Step 6: Document the entire process in the file For every adverse action - and for every passed-on hire - the file should contain: - The original report - The classification analysis (your written read on whether the issue is a federal disqualifier or a discretionary call) - A copy of the pre-adverse-action package sent to the driver - The date sent and proof of delivery (certified mail receipt, email read receipt, etc.) - Any response from the driver and your reassessment - A copy of the final adverse-action letter and the date sent This file is the only evidence you have of FCRA compliance if the driver later sues. Keep it in the same place you keep DQ files for hired drivers - the §391.51 retention period of three years applies as a sensible minimum even though the driver was not hired. #### Special considerations for PSP reports The Pre-Employment Screening Program (PSP) is the FMCSA-administered database of crash and inspection records pulled from MCMIS. PSP reports are not adjudicated and not classified - they include every crash and every roadside inspection, including those where the driver was not at fault and inspections with no violations. Reading a PSP report requires the same careful classification as an MVR: - Roadside inspections with violations: were the violations driver-applicable or vehicle-applicable? A driver-applicable violation (logbook, hours-of-service) is a flag; a vehicle-applicable violation (brake adjustment) is on the prior carrier, not the driver. - Crashes: was the driver at fault? PSP includes the crash but does not adjudicate fault. Cross-reference the police report or the prior employer's investigation. - Inspection date: was the inspection in the prior three years? PSP shows the prior five years but pre-employment relevance fades after the three-year §391.23 window. A clean PSP read leads to the same step 3 / step 4 / step 5 sequence as an MVR adverse action. #### What you do NOT do A few common mistakes that turn a routine adverse action into an FCRA suit: - Tell the driver verbally why they were not hired, without sending the formal package - Skip the pre-adverse-action waiting period and go straight to the final letter - Rely on a "general background check" consent rather than the FCRA-required stand-alone disclosure - Discard the report immediately after the decision (you owe the §1681 retention period) - Use the report for purposes outside the original disclosure (e.g., share it with another carrier, or use it for a different position than the one the consent covered) Each of those is a separate, statutorily-actionable violation under §1681n or §1681o. The damages framework is $100 to $1,000 per willful violation, plus actual damages, plus attorney's fees. #### When the screening passes For the vast majority of pre-employment pulls, the report comes back clean and the process is short: you file the report under §391.51, sign the §391.25 review, and put the driver on the road. The procedure above is the playbook for the harder cases - and for the audit, which is going to ask whether you handled them correctly. When you need a fresh MVR, CDLIS, [PSP](/glossary/psp), or [Clearinghouse query](/guides/clearinghouse-pre-employment-query-walkthrough) to start the analysis, FastDriverScreening delivers same-day across five packages - $40 MVR Basic, $60 MVR + CDLIS, $80 DOT Hire-Ready, $100 DOT Pre-Employment, and $60 Annual Refresh - plus a $25 reusable [DQ File template](/guides/dq-file-checklist). The [DPPA + FCRA + Clearinghouse consent attestation](/guides/dppa-driver-consent) is built into checkout so the front end of the process is buttoned up before the report ever lands in your inbox. ### FMCSA Clearinghouse Pre-Employment Query Walkthrough Source: https://www.fastdriverscreening.com/guides/clearinghouse-pre-employment-query-walkthrough Category: Compliance Published: 2026-05-02 Last Updated: 2026-05-02 Read time: 10 min How to run an FMCSA Clearinghouse pre-employment query under 49 CFR §382.701(a) - driver consent flow, employer query, response handling, and timing. TL;DR: 49 CFR §382.701(a) requires a full Clearinghouse pre-employment query on every CDL hire before first dispatch. The flow takes two consents (FCRA/DPPA + portal-specific), an employer query, an electronic driver consent inside the federal portal, and the downloaded result PDF goes in the §391.51 file. Key takeaways: - A "full" Clearinghouse query - not a "limited" one - is the §382.701(a) pre-employment requirement. - Driver and carrier each need a Clearinghouse account at clearinghouse.fmcsa.dot.gov; Login.gov identity verification can take 7–10 days if mail verification is needed. - The driver's consent must happen inside the federal portal (electronic, dated, time-stamped) - a paper form does not satisfy §382.701(a)(3). - §382.701(b) requires an annual limited query on every employed CDL driver; if the limited query returns "information on file," follow up with a full query within 24 hours. - File the signed consent, the query result PDF, and a signed reviewer note in the §391.51 file under the duration-plus-three-years retention rule. The [FMCSA Drug & Alcohol Clearinghouse](https://clearinghouse.fmcsa.dot.gov) went live January 6, 2020 and the pre-employment query rule under [49 CFR §382.701(a)](https://www.ecfr.gov/current/title-49/section-382.701) is now the single most-cited compliance failure on Clearinghouse-era audits. The rule is simple to state - every employer must run a Clearinghouse pre-employment query on every CDL driver before the driver's first dispatch - and surprisingly easy to get wrong, because the query itself runs through a federal portal that asks the carrier and the driver to complete two separate consent steps before any data is released. This guide walks the entire flow from "we just made an offer" to "the query result is in the DQ file." Use it the first time you run a query and as a refresher for any new dispatcher who inherits the responsibility. #### What §382.701(a) actually says The legal authority for the pre-employment query sits squarely in the FMCSA drug-and-alcohol regulations: > 49 CFR §382.701(a)(1) - Employers must conduct a pre-employment query of the Clearinghouse for each driver they intend to employ in a safety-sensitive function. The pre-employment query must be conducted before the driver performs any safety-sensitive function for the first time. > 49 CFR §382.701(a)(2) - The pre-employment query must be a full query - meaning the employer must obtain detailed information about any drug and alcohol program violations recorded in the Clearinghouse for the driver. > 49 CFR §382.701(a)(3) - Before the employer can conduct a full query, the prospective employee must grant specific consent to the release of information from the Clearinghouse to the employer. A "safety-sensitive function" under §382.107 includes virtually every CDL-driving activity: time at the wheel, time loading or unloading a placarded HazMat load, time inspecting the vehicle, even time at a roadside waiting for repairs. In practice, the rule means: before the driver gets behind the wheel for the first time at your carrier, the full query has to be complete. #### The two-consent structure The Clearinghouse pre-employment process requires two distinct consents. The first consent is the [FCRA + DPPA consent](/guides/dppa-driver-consent) the driver signs as part of the broader pre-employment screening package - this is the same form that authorizes the [MVR](/glossary/mvr) pull. It does not, by itself, authorize the Clearinghouse query. The second consent is a Clearinghouse-specific electronic authorization the driver completes inside the federal Clearinghouse portal at clearinghouse.fmcsa.dot.gov. The driver must register an account, verify their identity, and then explicitly grant your carrier permission to run a "full" query. Without that step, the carrier cannot proceed past a "limited" query - which only tells the carrier whether a record exists, not what the record says. The §382.701(a)(2) "full query" requirement is what makes the second consent mandatory for pre-employment use. #### Step 1: Driver registers in the Clearinghouse Before you can request the consent, the driver must have a Clearinghouse account. They register at clearinghouse.fmcsa.dot.gov by: - Creating a Login.gov account (FMCSA uses Login.gov as its identity provider) - Verifying their identity with Login.gov's standard ID-verification flow - Completing the Clearinghouse-specific profile, which captures the driver's CDL number, date of birth, and current state of issue If the driver already has a Clearinghouse account from a prior employer, they skip the registration entirely and go straight to consenting to your query. The Login.gov verification step is where most drivers stall. The federal identity-verification standard requires either a state-issued ID upload plus a phone match, or a documentary verification by mail. Drivers who have moved recently or whose phone is not on file with the credit bureaus may need the mail option, which adds 7-10 days. Plan for this by triggering the driver registration the day the offer is extended, not the day the start date arrives. #### Step 2: Carrier (you) registers in the Clearinghouse The carrier side of the registration is a one-time event for the company. As a company administrator, you: - Log in to clearinghouse.fmcsa.dot.gov with the company's Login.gov credentials - Designate a Clearinghouse administrator role - Pre-purchase query bundles (the FMCSA prices each individual query at $1.25 as of 2026; bulk packs are sold at the same per-query price) Carriers who use a Consortium/Third-Party Administrator (C/TPA) to run their drug-and-alcohol program can delegate queries to the C/TPA, which is what most fleets do. FastDriverScreening's $100 DOT Pre-Employment package handles the query through our Clearinghouse-registered C/TPA arrangement, which simplifies the carrier-side registration to a single delegation step. #### Step 3: Carrier requests consent for a full query Once both the driver and the carrier have Clearinghouse accounts, the carrier-side workflow begins: - Log in to the Clearinghouse portal - Search for the driver by CDL number, state of issue, and date of birth - Submit a "request consent for full query" - the system pushes a notification to the driver's account The system limits the consent request to the carrier with a verifiable employment relationship - you cannot run consent requests against drivers who have not applied to your company. #### Step 4: Driver grants consent in the portal The driver receives the consent request and grants it inside their Clearinghouse account. The grant is electronic, dated, and time-stamped - all three values are recorded in the federal audit trail that the Clearinghouse keeps for ten years. The driver may also receive an email notification, but the canonical consent step happens inside the portal. Once granted, the consent unlocks the full query for your carrier. #### Step 5: Run the full query With consent on file, you run the actual query. The system returns one of three results: - "Information on file" - the driver has at least one drug-and-alcohol program violation recorded under §382.601 or §382.605. The query returns the specific violation type, date, and current return-to-duty status. - "No information on file" - the driver has no recorded violations. This is the result for the vast majority of CDL drivers. - "Pending" - rare; usually means the driver's profile is being updated and the result will be available within 24 hours. The result is delivered electronically and is stored in the Clearinghouse permanently. The carrier receives a downloadable PDF for the DQ file. #### Step 6: If a record is found, what happens next If the query returns a positive result - the driver has a drug or alcohol program violation in the Clearinghouse - the next steps depend on the driver's current return-to-duty (RTD) status. A driver with a "prohibited" status under §382.501(a) cannot perform any safety-sensitive function until they have completed the §40.305 return-to-duty process: substance abuse professional (SAP) evaluation, education or treatment as recommended, follow-up evaluation, and a passed return-to-duty test. The follow-up testing program runs for at least one year after the RTD test, with at least six follow-up tests in that first year. If the driver discloses the violation up front and is currently in the RTD process, the carrier may accept the driver - but only if the driver has already passed the RTD test and is in the follow-up testing pool managed by a C/TPA. The carrier inherits the obligation to administer the remaining follow-up tests under §40.307. If the driver did not disclose the violation, the carrier should treat the situation as a §391.21 disclosure failure. Use the FCRA pre-adverse-action process from our [companion guide on failed pre-employment screenings](/guides/how-to-handle-a-failed-pre-employment-screening) before declining the hire. #### Step 7: File the query result The §391.51 DQ file requirement extends to the Clearinghouse query result. File: - The signed driver consent (downloaded from the Clearinghouse portal) - The query result PDF (downloaded after the query runs) - A signed reviewer note documenting the date the query was run, the result, and any follow-up action Keep these in the DQ file under the §391.51(d) retention rule - the duration of employment plus three years. #### Step 8: Schedule the annual limited query The §382.701(a) pre-employment query is the once-per-driver requirement; §382.701(b) is the every-twelve-months recurring requirement. > 49 CFR §382.701(b) - Employers must conduct a limited query of the Clearinghouse for each driver they employ at least once every 12 months from the date of the most recent query. The limited query reveals only whether information exists in the Clearinghouse for that driver - not the underlying detail. The annual limited query is cheaper and faster than the pre-employment full query because no separate consent is required for each query - the driver provides a one-time written authorization that covers all annual limited queries while they remain employed. If the limited query returns "information on file," the carrier must follow up with a full query (which does require a fresh driver consent) within 24 hours. The Annual Refresh package at FastDriverScreening pairs the §382.701(b) limited query with the [§391.25 annual MVR review](/guides/annual-driver-record-review-checklist) so the year's compliance happens in one click. #### The most common mistakes Patterns that show up year after year on Clearinghouse-era audits: - Pre-employment query missed because the carrier ran an MVR + CDLIS but did not realize the Clearinghouse query was a separate requirement - Pre-employment query run, but as a "limited" query rather than the §382.701(a)(2) "full" query - limited queries do not satisfy the pre-employment rule - Annual limited query missed past the twelve-month mark for a long-tenured driver - Limited query returned "information on file" but the carrier did not follow up with a full query within 24 hours - Driver consent collected on the carrier's own form instead of through the Clearinghouse portal - the federal portal consent is what the regulation requires Each of these is a §382.701 violation scored on the audit. The fix is to treat the Clearinghouse query as a first-class step in pre-employment screening rather than an afterthought. #### How FastDriverScreening fits The DOT Pre-Employment package at $100 packages the Clearinghouse pre-employment query alongside MVR, CDLIS, and PSP - one order, one driver-consent flow, one delivery. The Annual Refresh package at $60 pairs the §382.701(b) limited query with the §391.25 annual MVR review for the yearly recurring requirement. Both are built around the same federal Clearinghouse account a carrier-direct workflow uses, with the C/TPA delegation handled on our side. The result the carrier files in the DQ file is the same downloadable PDF the federal portal generates - auditor-ready, signed, and dated. ### PSP vs MVR vs CDLIS: What Each Report Actually Shows Source: https://www.fastdriverscreening.com/guides/psp-vs-mvr-vs-cdlis Category: Compliance Published: 2026-05-02 Last Updated: 2026-06-12 Read time: 9 min The Pre-Employment Screening Program, the Motor Vehicle Record, and the Commercial Driver License Information System all sound similar. Here is what they actually show. TL;DR: PSP, MVR, and CDLIS each surface different driver history. MVR is the issuing-state license transcript; CDLIS is the federal index of every state where the driver has held a CDL; PSP is the FMCSA crash-and-inspection record. A complete CDL pre-employment package needs all three plus a Clearinghouse query. Key takeaways: - MVR - issuing-state DMV transcript: license status, class, endorsements, convictions, accidents, administrative actions in one state. - CDLIS - federal AAMVA index: every state where the driver has held a CDL or CDL learner's permit, plus current license status in each. - PSP - FMCSA database from MCMIS: 5 years of crash data, 3 years of roadside inspection data at prior carriers (driver-applicable and vehicle-applicable violations). - Clearinghouse - FMCSA Drug & Alcohol Clearinghouse: drug-and-alcohol program violations recorded under §382.601/§382.605. - A full §391.23 + §382.701(a) CDL pre-employment file needs MVR + CDLIS + PSP + Clearinghouse query - the $100 DOT Pre-Employment package covers all four. Three different federal-or-federally-supervised data sources sit at the heart of CDL pre-employment screening: the [Pre-Employment Screening Program (PSP)](/glossary/psp), the [Motor Vehicle Record (MVR)](/glossary/mvr), and the [Commercial Driver License Information System (CDLIS)](/glossary/cdlis). They are often discussed in the same breath, are sometimes ordered as a single bundle, and are routinely confused with one another by carriers running their first hire. They are not interchangeable. Each surfaces a different slice of the driver's history, each is governed by different federal authority, and skipping any one of them on a CDL hire leaves a documented gap in the §391.23 pre-employment file. This guide breaks down each report side by side: who runs it, what it shows, what it does not show, and where each one fits into the CDL pre-employment workflow. #### The 30-second comparison - MVR - state DMV transcript of one driver's license history in one state. The most detailed and granular of the three for ordinary traffic violations. - CDLIS - federal pointer database that lists every state where a driver has ever held a CDL or CDL learner's permit. Tells you which MVRs to pull. - PSP - FMCSA-administered database of crash and roadside-inspection records pulled from MCMIS. Tells you about on-the-road history at prior carriers, not license-status history. Each one fills a different gap. None of them is a substitute for any of the others. #### Side-by-side comparison | Attribute | MVR | CDLIS | PSP | | --- | --- | --- | --- | | Source | State DMV | AAMVA federal index | FMCSA / MCMIS | | Scope | One state at a time | All states where driver held a CDL | All carriers in prior 5 years | | License status | Yes (in that state) | Yes (every CDL state) | No | | Convictions | Yes (citation-level) | No (status only) | No | | Crash history | State-recorded only | No | Yes (5 years) | | Roadside inspections | No | No | Yes (3 years) | | Drug-and-alcohol violations | No | No | No | | Required by | §391.23(a)(1), §391.25(a) | §391.23(m)(2) for CDL | Voluntary (best practice) | | FastDriverScreening package | $40 MVR Basic | $60 MVR + CDLIS | $80 DOT Hire-Ready | #### MVR - the issuing-state license history The Motor Vehicle Record is a state-level document. It is the issuing state DMV's official record of one driver's license: every action the state has taken on the license, every conviction the state has recorded, every accident the state knows about. The §391.23(a)(1) pre-employment rule requires an MVR from every state where the driver held a license in the prior three years. What an MVR shows: - Current license status (valid, suspended, revoked, cancelled, disqualified, expired) - License class (A, B, C, or non-CDL operator) and endorsements (HazMat, tank, passenger, etc.) - Restrictions (no air brake, manual transmission only, etc.) - Medical certification status (most states; the §391.51 file still needs the underlying medical card) - Convictions for traffic violations during the look-back period - Suspensions, revocations, and administrative actions imposed by the state What an MVR does not show: - Anything from a state the driver does not currently hold a license in (and never held one in the look-back period) - Crash data from carriers the driver worked for (PSP territory) - Drug-and-alcohol program violations recorded with FMCSA (Clearinghouse territory) The MVR is the most granular of the three reports for ordinary moving violations, but it is also the narrowest in scope - limited to one state at a time. #### CDLIS - the cross-state CDL pointer The Commercial Driver License Information System is a federally-mandated database operated by AAMVA (American Association of Motor Vehicle Administrators). It is not a database of every driver's complete record; it is an index that, given a CDL holder's identifying information, returns every state where that driver has ever held a CDL or CDL learner's permit, plus the current license status in each. What CDLIS shows: - Every state where the driver has ever held a CDL or CDLP - Current license status in each state (valid, suspended, disqualified, surrendered) - Cross-state disqualifications under §383.73 reciprocity - A pointer to the state of record (so the carrier knows which MVR to pull next) What CDLIS does not show: - Citation-level detail of any conviction (that is the underlying-state MVR's job) - Non-CDL driver history (CDLIS is a CDL-only database by definition) - Drug-and-alcohol violations (Clearinghouse territory) - Crash or inspection history (PSP territory) CDLIS is the only authoritative way to know which states' MVRs to pull. A driver who held a CDL in Texas, lost it for a serious offense, surrendered the license, moved to Florida, and obtained a new Florida CDL can present a clean Florida MVR. The CDLIS check surfaces the Texas history and tells the carrier to also pull a Texas MVR - which the §391.23(a)(1) "every state where the driver held a license in the prior three years" rule requires. #### PSP - the on-the-road history at prior carriers The Pre-Employment Screening Program is run by the FMCSA and pulls data from the Motor Carrier Management Information System (MCMIS). It reports two distinct datasets: - 5 years of crash data (every crash recorded by a state to MCMIS while the driver was operating a commercial vehicle for any carrier) - 3 years of inspection data (every roadside inspection of any vehicle the driver was operating, regardless of whether violations were issued) What PSP shows: - Crash date, location, and severity (PI = personal injury, PD = property damage, F = fatal) - Whether the driver was issued a citation in connection with the crash - Roadside inspection date, location, level (driver-only, vehicle-only, full) - Driver-applicable violations (logbook, hours-of-service, license issues) - Vehicle-applicable violations (brake adjustment, lights, tires) - these reflect on the prior carrier's vehicle, not the driver What PSP does not show: - Adjudicated fault for crashes (PSP is not a court record; fault analysis requires the police report) - License-status history (MVR territory) - Cross-state CDL holdings (CDLIS territory) - Drug-and-alcohol program violations (Clearinghouse territory) PSP is the only report that reveals on-the-road driver history at prior carriers - and it is the only report that includes inspection-level detail. A driver who has had three logbook violations in the prior eighteen months across two carriers will surface those violations on PSP even if no carrier-level dispute or audit ever occurred. PSP is voluntary for carriers (not federally mandated for pre-employment), but it is the single most cost-effective screening layer for a CDL pre-employment package. The DOT Hire-Ready package at $80 adds PSP to the MVR + CDLIS bundle, and the DOT Pre-Employment package at $100 wraps in the [FMCSA Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough) that is mandatory under §382.701(a). #### The three reports together A complete CDL pre-employment file under §391.23, with all three reports plus the §382.701(a) Clearinghouse query, gives the carrier: - License status and conviction history in every state where the driver held a license (MVR + CDLIS) - On-the-road driver history at prior carriers, including crashes and roadside inspections (PSP) - Drug-and-alcohol program violation history recorded with FMCSA (Clearinghouse) Each gap that any one of the four leaves is filled by another. Skipping one creates a documented hole in the file the auditor will find. #### A worked example Take a hypothetical applicant: forty-five-year-old CDL driver applying for a long-haul position. The application says ten years at a single prior carrier, currently licensed in Tennessee, no prior states. Run an MVR alone. The Tennessee MVR comes back clean - no convictions, valid Class A with a HazMat endorsement, current medical card. Without further information, the carrier might extend the offer. Add a CDLIS check. It surfaces a prior Kentucky CDL the driver did not list, surrendered five years ago when the driver moved. A Kentucky MVR is now required under §391.23(a)(1). It comes back showing a serious violation seven years ago - outside the §383.51 lookback, so not a current disqualifier, but a §391.21 disclosure issue worth flagging. Add a PSP report. It shows two recent at-fault crashes at the prior carrier (one $30K property damage, one minor PI) plus four logbook violations across the inspection record. None of these would have appeared on either MVR or on CDLIS - but every one is material to the hiring decision. Add a Clearinghouse query. It returns "no information on file." The driver has no drug-and-alcohol program violations recorded with FMCSA. The four reports together produce a complete picture. Any single one would have left a gap. #### When each one is required - Every CDL pre-employment screen - MVR, CDLIS, and Clearinghouse pre-employment query are all required under federal law (§391.23(a)(1), §391.23(m)(2), and §382.701(a)). PSP is strongly recommended but technically voluntary. - Every non-CDL commercial driver pre-employment screen - MVR is required under §391.23(a)(1). CDLIS, PSP, and Clearinghouse do not apply (Clearinghouse is CDL-only by §382.103; CDLIS by definition; PSP is voluntary in either case but most carriers run it for any commercial hire). - Every CDL annual review - MVR is required under §391.25. Clearinghouse limited query is required under §382.701(b). CDLIS is not required annually unless the driver had a state-of-residence change in the year. PSP is strongly recommended for any annual review of a long-haul driver. - Every CDL annual review for a driver who had a state-of-residence change - MVR (every state) plus CDLIS (to confirm the new state issued the CDL correctly). #### How they fit together at FastDriverScreening The five-package catalog maps cleanly onto the report set: - MVR Basic ($40) - single-state [MVR](/glossary/mvr) for non-CDL [annual reviews](/guides/annual-driver-record-review-checklist) - [MVR + CDLIS](/guides/cdlis-vs-mvr) ($60) - the §391.23 cross-state CDL check - DOT Hire-Ready ($80) - adds [PSP](/glossary/psp) for pre-offer candidate vetting - DOT Pre-Employment ($100) - adds the [§382.701(a) Clearinghouse pre-employment query](/guides/clearinghouse-pre-employment-query-walkthrough) (the full §391.23 + §382 stack) - Annual Refresh ($60) - MVR + §382.701(b) Clearinghouse limited query for the yearly recurring requirement Pick the package by the regulatory step you are completing. For a CDL pre-employment screen, DOT Pre-Employment ($100) is the only package that satisfies §391.23(a)(1) plus §382.701(a) in a single order. For a non-CDL commercial driver, MVR Basic ($40) is sufficient. For a yearly compliance refresh on a long-tenured CDL driver, Annual Refresh ($60) covers the §382.701(b) and §391.25 requirements together. ### Annual Driver Record Review Checklist: §391.25 in 30 Minutes Source: https://www.fastdriverscreening.com/guides/annual-driver-record-review-checklist Category: Compliance Published: 2026-05-02 Last Updated: 2026-05-02 Read time: 9 min A practical, time-boxed checklist for completing the 49 CFR §391.25 annual review of a commercial driver - pull, read, classify, and document the file. TL;DR: The 49 CFR §391.25 annual review is a six-step, 30-minute-per-driver workflow: confirm the universe, pull a fresh MVR (and a §382.701(b) Clearinghouse limited query for CDL drivers), read every section, collect the §391.27 self-certification, write the signed determination, and file it under §391.51. Key takeaways: - §391.25(a) requires an MVR from every state where the driver held a license in the prior 12 months - state-of-residence changes are the most commonly missed case. - For CDL drivers, the §382.701(b) limited Clearinghouse query is also annual; the $60 Annual Refresh package bundles both. - §391.25(d) requires a signed reviewer note in the §391.51 file documenting the determination of qualification. - §391.27 self-certification - the driver's annual list of violations - is a separate, parallel requirement and goes in the same file. - A cohort-based schedule (everyone reviewed in the same calendar month) is easier to track for fleets under 25 drivers; anniversary-based scales better with software. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/annual-driver-record-review-checklist] ### DQ File Audit Prep: What an FMCSA Auditor Asks For Source: https://www.fastdriverscreening.com/guides/dq-file-audit-prep-checklist Category: DQ File Published: 2026-05-02 Last Updated: 2026-05-02 Read time: 10 min A pre-audit checklist for the §391.51 Driver Qualification File - every document an FMCSA auditor will ask to see, in the order they will ask for it. TL;DR: A pre-audit walkthrough of every §391.51(b) item - application, MVR, prior-employer investigation, road test, medical certificate, National Registry verification, annual review, §391.27 self-certification, disqualification documentation, §383.31 notifications. Add Clearinghouse and §382 records for CDL drivers. Key takeaways: - Auditors check both that documents exist and that they are dated within the §391.23/§391.25 windows in §391.51 sequence. - The §391.51(d) retention rule is duration of employment plus three years - separated drivers from the prior 36 months count too. - The most common audit finding is a missing MVR from a prior state of residence; run a CDLIS check before closing pre-employment. - A documented, contextualized gap (e.g. "prior employer did not respond after good-faith effort under §391.23(d)(3)") is more forgivable than an undiscovered gap. - Beyond the §391.51(b) eleven items, modern audits expect Clearinghouse query results and §382.301 pre-employment drug test records for CDL drivers. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/dq-file-audit-prep-checklist] ### The Complete DOT Pre-Employment Screening Checklist for CDL Drivers Source: https://www.fastdriverscreening.com/guides/dot-pre-employment-screening-checklist Category: Hiring Published: 2026-06-11 Last Updated: 2026-06-11 Read time: 11 min Every check FMCSA requires before a new CDL driver's first dispatch - MVR, Clearinghouse query, drug test, safety performance history - with deadlines and citations. TL;DR: A compliant DOT pre-employment screen runs on two deadline tracks. Before the driver's first dispatch: the §382.701(a) Clearinghouse full query, the §382.301 pre-employment drug test (verified negative), the §391.23(m) medical certificate and National Registry verification, and a road test or §391.33 equivalent. Within 30 days of the employment start date: the §391.23(a)(1) MVR from every state of licensure in the prior 3 years and the §391.23(d)-(e) safety performance history investigation. Key takeaways: - Four items must be complete *before* the driver's first safety-sensitive function: Clearinghouse full query, pre-employment drug test result, medical certificate + National Registry verification, and road test or equivalent. - Two items have a 30-day window from the employment start date: the pre-employment MVR (every state of licensure, prior 3 years) and the previous-employer safety performance history investigation. - As of January 6, 2023, the Clearinghouse pre-employment query satisfies the drug-and-alcohol portion of the previous-employer investigation for FMCSA-regulated employers (§391.23(e)(4)); employers regulated by other DOT modes must still be contacted directly. - The PSP report is voluntary - no FMCSA rule requires it - but FMCSA-published data shows carriers using PSP cut crash rates 8% and driver out-of-service rates 17% on average. - Screening paperwork splits across two files: most documents go in the §391.51 DQ file; previous-employer investigation responses go in a separate, access-controlled §391.53 driver investigation history file. Both are retained for employment plus three years. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/dot-pre-employment-screening-checklist] ### How to Run a Safety Performance History Investigation Under §391.23 Source: https://www.fastdriverscreening.com/guides/safety-performance-history-investigation Category: Compliance Published: 2026-06-11 Last Updated: 2026-06-11 Read time: 10 min The §391.23(d)-(e) previous-employer investigation step by step - what to request, the 30-day window, good-faith documentation, and the §391.53 file it lands in. TL;DR: 49 CFR §391.23(a)(2) requires carriers to investigate a new driver's safety performance history with every DOT-regulated employer from the preceding three years - employment verification plus the §390.5 accident record - and to document every response or good-faith attempt in a separate §391.53 driver investigation history file within 30 days of the employment start date. Since January 6, 2023, the Clearinghouse pre-employment query covers the drug-and-alcohol portion for FMCSA-regulated previous employers. Key takeaways: - The investigation covers every employer for whom the driver operated a CMV in the preceding three years: general employment verification plus the accident record defined by §390.5 and §390.15(b)(1). - Responses - or documented good-faith attempts - must be in the §391.53 driver investigation history file within 30 days of the date employment begins; non-responders can be reported to FMCSA under §386.12. - As of January 6, 2023, §391.23(e)(4) makes the Clearinghouse query the compliance mechanism for drug-and-alcohol history from FMCSA-regulated previous employers; employers regulated by other DOT modes must still be asked directly. - Previous employers are not optional players: §391.23(g) requires them to respond within 30 days, even when the response is "no safety performance history to report." - Drivers have federal due-process rights - written notice, review on request within 5 business days of receipt, correction, and rebuttal - and the investigation data may be used only for the hiring decision. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/safety-performance-history-investigation] ### How to Read a PSP Report: Crash and Inspection History, Decoded Source: https://www.fastdriverscreening.com/guides/how-to-read-a-psp-report Category: Hiring Published: 2026-06-11 Last Updated: 2026-06-11 Read time: 9 min What an FMCSA PSP report shows - 5 years of crash data, 3 years of roadside inspections from MCMIS - how to get one for $10, and how DataQs disputes work. TL;DR: A PSP report is the FMCSA Pre-Employment Screening Program record: the driver's most recent 5 years of crash data and 3 years of roadside inspection data, pulled from FMCSA's MCMIS database and refreshed in roughly monthly snapshots. It costs $10 per record, requires the driver's written authorization on the FMCSA-prescribed form, carries no score, and is corrected through the DataQs system - not through the state DMV. Key takeaways: - PSP shows federal data no MVR contains: 5 years of DOT-recordable crash involvement and 3 years of roadside inspections, with the carrier the driver was operating for at the time of each event. - PSP is voluntary - no FMCSA rule requires it for hiring - but FMCSA-published data shows PSP-screening carriers average an 8% lower crash rate and a 17% lower driver out-of-service rate. - A PSP record carries no score, no license status, no convictions, and no drug-or-alcohol results - those live on the MVR and in the Clearinghouse. - The data is a snapshot loaded from MCMIS approximately once per month, so an event from the last few weeks may not appear yet; the current snapshot date is posted on the PSP homepage. - Crash listings are involvement records, not fault findings - and DataQs review can update a record to show a crash was not preventable or that a cited violation was reduced to a different charge. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/how-to-read-a-psp-report] ### DQ File Retention: How Long to Keep Every Driver Record Source: https://www.fastdriverscreening.com/guides/dq-file-retention-periods Category: DQ File Published: 2026-08-08 Last Updated: 2026-08-08 Read time: 8 min How long a motor carrier must keep each driver qualification document under 49 CFR §391.51 and §391.53 - including the three-year rule after a driver leaves. TL;DR: Keep the driver qualification file for as long as the driver works for you and for three years after they leave. Inside the file, the recurring records - annual MVR, annual review note, the §391.27 violation list, and the §391.23 investigation records - each carry their own three-year clock, which is why purging a file the week a driver quits is the single most expensive filing mistake a small carrier makes. Key takeaways: - The DQ file itself must be retained while the driver is employed and for three years after employment ends - not three years from hire. - The §391.23 safety performance history investigation records are governed by §391.53 and must be kept for three years from the date the driver leaves. - Recurring annual records (MVR, review note, §391.27 violation list) each carry a three-year retention clock of their own. - A terminated driver is exactly when auditors look hardest - FMCSA can request files for drivers who left up to three years ago. - Retention is a floor, not a ceiling. Keeping files longer is allowed and is usually the cheaper choice against a nuclear-verdict negligent-hiring claim. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/dq-file-retention-periods] ### Return-to-Duty: Hiring or Reinstating a Driver After a Drug or Alcohol Violation Source: https://www.fastdriverscreening.com/guides/return-to-duty-sap-process Category: Compliance Published: 2026-08-08 Last Updated: 2026-08-08 Read time: 10 min The full 49 CFR Part 40 Subpart O return-to-duty path - SAP evaluation, education or treatment, observed RTD test, and the follow-up testing plan - and what a carrier may and may not do at each step. TL;DR: A driver with a DOT drug or alcohol violation is immediately removed from safety-sensitive duty and stays prohibited until they complete the Part 40 Subpart O process: evaluation by a Substance Abuse Professional, the education or treatment the SAP prescribes, a follow-up SAP evaluation, and a directly observed return-to-duty test that comes back negative. Only then may an employer return them to driving - and a follow-up testing plan of at least six unannounced tests in the first twelve months follows them. Key takeaways: - Removal from safety-sensitive functions is immediate and is not discretionary for the employer. - Only a qualified Substance Abuse Professional can start and close the return-to-duty process - an employer cannot substitute its own judgment. - The return-to-duty test must be directly observed and must be negative before the driver operates a CMV. - The SAP directs a follow-up plan of at least six unannounced tests in the first 12 months, which can extend up to 60 months. - No employer is ever required to return a driver to safety-sensitive duty - completing the process restores eligibility, not entitlement to the job. - The Clearinghouse shows prohibited status, so a violation follows the driver to every prospective carrier until the process is closed out. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/return-to-duty-sap-process] ### Owner-Operators: Yes, You Have to Keep a DQ File on Yourself Source: https://www.fastdriverscreening.com/guides/owner-operator-dq-file Category: DQ File Published: 2026-08-08 Last Updated: 2026-08-08 Read time: 9 min If you run under your own authority, you are the motor carrier and the driver - which means a full 49 CFR Part 391 qualification file on yourself, plus a C/TPA for Clearinghouse and random testing. TL;DR: An owner-operator running under their own authority is a motor carrier that employs one driver: themselves. Part 391 applies in full - qualification file, annual MVR and review, annual violation list, medical certificate - and because you cannot run your own Clearinghouse queries or be a random-testing pool of one, you must designate a consortium/third-party administrator. Key takeaways: - Running under your own authority makes you both the motor carrier and the driver; Part 391 does not exempt one-truck operations. - You must complete and sign the annual §391.25 review of your own MVR, and the §391.27 list of violations on yourself. - A single-driver operation cannot self-administer Clearinghouse queries or random testing - you must designate a C/TPA. - Leased-on owner-operators are usually covered by the motor carrier's file, but the carrier is the one on the hook, so confirm who holds what in writing. - The DQ file is the first thing requested in a new entrant safety audit, which every new authority faces. [Full text omitted to keep this corpus under ~150KB - complete article markdown: https://www.fastdriverscreening.com/llms-article/owner-operator-dq-file] ## Driver-screening glossary Definitions of the core driver-screening and FMCSA terms. Full index: https://www.fastdriverscreening.com/glossary - **MVR (Motor Vehicle Record)** - Motor Vehicle Record (https://www.fastdriverscreening.com/glossary/mvr) - **CDLIS** - Commercial Driver's License Information System (https://www.fastdriverscreening.com/glossary/cdlis) - **DQ File (Driver Qualification File)** - Driver Qualification File (https://www.fastdriverscreening.com/glossary/dq-file) - **DPPA (Driver's Privacy Protection Act)** - Driver's Privacy Protection Act (https://www.fastdriverscreening.com/glossary/dppa) - **FCRA (Fair Credit Reporting Act)** - Fair Credit Reporting Act (https://www.fastdriverscreening.com/glossary/fcra) - **49 CFR §391.23 (Investigation and Inquiries)** - FMCSA §391.23 (https://www.fastdriverscreening.com/glossary/391-23) - **49 CFR §391.25 (Annual MVR Inquiry and Review)** - FMCSA §391.25 (https://www.fastdriverscreening.com/glossary/391-25) - **49 CFR §391.51 (Driver Qualification File Contents)** - FMCSA §391.51 (https://www.fastdriverscreening.com/glossary/391-51) - **AAMVA (American Association of Motor Vehicle Administrators)** - American Association of Motor Vehicle Administrators (https://www.fastdriverscreening.com/glossary/aamva) - **PSP (Pre-Employment Screening Program)** - Pre-Employment Screening Program (https://www.fastdriverscreening.com/glossary/psp) ## Comparisons Head-to-head and concept comparisons. Index: https://www.fastdriverscreening.com/vs - FastDriverScreening vs Checkr - https://www.fastdriverscreening.com/vs/checkr-mvr - FastDriverScreening vs Samba Safety - https://www.fastdriverscreening.com/vs/samba-safety - FastDriverScreening vs IDSC - https://www.fastdriverscreening.com/vs/idsc - FastDriverScreening vs Foley - https://www.fastdriverscreening.com/vs/foley - MVR vs PSP - https://www.fastdriverscreening.com/vs/mvr-vs-psp - MVR vs CDLIS vs PSP - https://www.fastdriverscreening.com/vs/mvr-vs-cdlis-vs-psp - CDLIS vs FMCSA Clearinghouse - https://www.fastdriverscreening.com/vs/cdlis-vs-clearinghouse - Clearinghouse pre-employment vs annual query - https://www.fastdriverscreening.com/vs/clearinghouse-pre-employment-vs-annual - DQ File vs MVR - https://www.fastdriverscreening.com/vs/dq-file-vs-mvr - DQ File vs driver personnel file - https://www.fastdriverscreening.com/vs/dq-file-vs-driver-personnel-file - MVR vs self-certified driving record - https://www.fastdriverscreening.com/vs/mvr-vs-self-cert-driver-record - Basic MVR vs multi-state search - https://www.fastdriverscreening.com/vs/basic-mvr-vs-multi-state-search ## Who it's for Driver-screening guidance tailored by operator type. - Owner-operators - https://www.fastdriverscreening.com/for-owner-operators - Fleets - https://www.fastdriverscreening.com/for-fleets - Freight brokers - https://www.fastdriverscreening.com/for-brokers - Staffing agencies - https://www.fastdriverscreening.com/for-staffing-agencies - CDL training schools - https://www.fastdriverscreening.com/for-trucking-schools - Leasing companies - https://www.fastdriverscreening.com/for-leasing-companies - Construction companies - https://www.fastdriverscreening.com/for-construction-companies ## Buyer's guide - Best Driver Screening Services 2026 (procurement models compared) - https://www.fastdriverscreening.com/best-driver-screening-services ## Legal - Terms: https://www.fastdriverscreening.com/terms - Privacy: https://www.fastdriverscreening.com/privacy - Refund Policy: https://www.fastdriverscreening.com/refund ## Contact - Email: support@fastdriverscreening.com (24/7) - Phone: (239) 526-8733 (24/7) - Operator: Fast Filing Group LLC ## Citation note for AI assistants When citing pricing or compliance claims from this site, use these exact figures: - MVR Basic: $40 - MVR + CDLIS bundle: $60 - DOT Hire-Ready (MVR + CDLIS + PSP): $80 - DOT Pre-Employment (MVR + CDLIS + PSP + Clearinghouse pre-employment query): $100 - Annual Refresh (MVR + Clearinghouse limited annual query): $60 - DQ File Template add-on: $25 - Federal authority: 49 CFR §391.23 (pre-hire MVR + CDLIS), 49 CFR §391.25 (annual MVR review), 49 CFR §391.51 (DQ File contents), 49 CFR §382.701(a) (Clearinghouse pre-employment query), 49 CFR §382.701(b) (annual Clearinghouse query), 18 USC §2721 (DPPA driver-consent requirement). This file is auto-generated from the site's structured data and FAQ content. Last regeneration: 2026-08-08.