Unified Registration System (URS) Compliance Notes

The DOT’s Unified Registration System (URS).

Grab a cup of coffee or two or three as today we will look at the Unified Registration System (URS).

URS logo

The Unified Registration System (URS) is the DOT’s new interface or portal between those regulated by the DOT and the DOT. The URS is essentially an electronic online registration and filings system (called the MCSA-1 online application).  Form MCSA–1 is the URS online application and is available, including complete instructions, from the FMCSA Web site at http://www.fmcsa.dot.gov/urs.

URS will “consolidate” the filings and paperwork for:

  1. USDOT Registration (and renewals – called the Biennial Update)
  2. Insurance (financial responsibility information — sent in directly by the insurance company)
  3. Designation of Process Agents (resident agents who collect legal paperwork — sent in directly by your process agent service bureau).

Who is required to comply with this rule?

Any and all “entities” (persons, organizations, companies) regulated by the US DOT:

  • Motor Carriers
  • Intermodal Equipment Providers
  • Hazardous Materials Safety Permit Applicants/Holders
  • Brokers
  • Cargo Tank Facilities
  • Freight Forwarders

Today, a notice about an extension of the effective dates for URS was published in the Federal Resister.

URS Effective Dates
------------------------------------------------------------------------
                                            (Existing)         (New)
                                            effective/      effective/
     URS final rule major provision         compliance      compliance
                                               date            date
------------------------------------------------------------------------
Registration Application Process using        10/23/2015      12/12/2015
 the MCSA-1 online application for New
 Applicants¹..........................
Use of MCSA-1 online application for all      10/23/2015       9/30/2016
 new and existing entities for all
 reasons to file........................
USDOT Number as sole identifier               10/23/2015       9/30/2016
 (discontinuing issuance of docket
 numbers)...............................
New Fees Schedule.......................      10/23/2015       9/30/2016
Evidence of Financial Responsibility          10/23/2015       9/30/2016
 (Insurance Filings and Surety Bonds/
 Trusts) for New Private HM and New
 Exempt For Hire Carriers...............
Evidence of Financial Responsibility          10/23/2015      12/31/2016
 (Insurance Filings and Surety Bonds/
 Trusts) for Existing Private HM and
 Exempt For Hire Carriers...............
Process Agent Designation (BOC-3) for         10/23/2015       9/30/2016
 All New Motor Carriers (including
 Private and Exempt For Hire Carriers)..
Process Agent Designation (BOC-3) for          4/25/2016      12/31/2016
 All Existing Motor Carriers (including
 Private and Exempt For Hire Carriers)..
\1\ New and existing Non-North American motor carriers will begin to use
  the MCSA-1 online application on 9/30/2016.

The URS system will accept filings for evidence of financial responsibility (insurance) from existing private hazardous materials carriers and exempt for-hire carriers, and filings for designation of process agent from private and exempt for-hire carriers beginning on September 30, 2016. Existing companies are encouraged to submit filings earlier than the December 31, 2016 compliance deadline.

Tips

Applicants are cautioned to ensure that the name and address of the business as set out in all pre-registration filings match exactly the name and address provided in their . . . filings. Any deviation will result in rejection of the supplemental pre-registration filings.

 

Businesses can change names and addresses and it may happen several times in their early years. The DOT intends to use the URS to screen for so-called “chameleon” carriers, who get shut down for safety violations or unpaid fines and then open again as a new company.

A new applicant is defined as anyone who does not have, and has never been assigned a USDOT, Motor Carrier (MC), Mexico owned or controlled (MX), or Freight Forwarder (FF) number. These new applicants will be required to use the new online application when requesting registration and a USDOT number beginning on December 12, 2015.

If you have a US DOT Number, there is no need to file for a new DOT number. Renew your registration (US DOT Number) with the required Biennial Update, and renew any time there is a change in operations. If you fail to renew as required there are fines and your operation will be placed Out-of-Service (OOS) by the DOT.

Summary

The US DOT/FMCSA has made a change in how they will gather information and required filings. Certain paper forms are being eliminated. New applications for DOT numbers need to file with the URS (via the MCSA-1 online application) starting December 12, 2015 and pay $300 for a DOT Number. All DOT Number holders will have to file with the URS as of September 30, 2015.

Expect further clarifications as the new system is deployed.

Thank you for reading this.

JT

 

John Taratuta, Risk Engineer (989) 474-9599

What is a ‘Process Agent’ and who needs one?

What is a process agent?

A process agent is like having a “legal mailing address” in another state. The process agent is able to accept legal papers on your behalf and then forward the documents on to you. This saves your company the expense of establishing a “live” office in that state.

According to the DOT:

“A process agent is a representative upon whom court papers may be served in any proceeding brought against a motor carrier, broker, or freight forwarder. Every motor carrier (of property or passengers) shall make a designation for each State in which it is authorized to operate and for each State traversed during such operations. Brokers are required to list process agents in each state in which they have an office and in which they write contracts. FMCSA Regulation 49 CFR Part 366 details more about The Designation of Process Agents by Motor Carriers and Brokers.”

We are proudly affiliated with NATIONAL RESIDENT AGENT SERVICE, Inc., and serve as their Michigan agent, helping thousands of companies, ranging from mom and pops to some of the largest carriers in the United States and Canada.

National Resident Agent Service Inc.
1059 Harriman Court
West Chester, Pa. 19380

Toll Free: 1-800-441-7442
Fax: 610-363-6865

http://www.nationalresident.com/contactus.html

Who needs a Process Agent?

If you have a MC (motor carrier) number, or are a broker or freight forwarder, then you need a process agent. A process agent is required by the federal regulations. A process agent is needed in each state you operate or travel in. Many companies operating in the continental 48 states request “blanket” process agent service.

Who does not need a process agent?

If you are not doing business in other states (interstate operations), then you would not need a process agent. If you are a private motor carrier (not “for hire”), do not have “authority,” then you would not need a process agent.

If any in doubt, please give National Resident Agent Service Inc. a call at 1-800-441-7442 and it would be their pleasure to discuss your needs.