Tuesday, October 8, 2013

Biennial Reports/URS Rulemaking Requires Careful Consideration

On August 23, 2013, the FMCSA issued its Final Rule in the Unified Registration System (URS) matter.  This rulemaking will make massive changes to the application process effective in March of 2015.

In the meantime, two aspects of the Final Rule are effective.  One is a substantial penalty for failing to file the biennial MCS-150 report on time leading up to and including revocation of authority.

The other aspect of the Rule, which is effective October 23, 2013 will eliminate transfer applications but extend reporting requirements to an informal notice procedure which will include change of ownership and control of regulated entities – a new agency mandated requirement for which there is no statutory authority. An analysis of the URS rulemaking is attached.

In addition, the FMCSA is holding free webinars to educate affected parties on the biennial update requirement.  All affected parties are advised to listen to one of these webinars to ensure compliance. Click here to view

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