New Entrant Audit

Guide · the yearly duties

The annual MVR and the annual review — two duties, both under §391.25

The completions for "annual mvr" are carriers discovering a duty that has no invoice and no reminder attached to it. Every 12 months, for every driver, §391.25 requires two things — and the second one is the one everybody misses.

Duty 1 — pull the record (§391.25(a))

At least once every 12 months, obtain the driver's motor vehicle record from every state that issued him a license in that period. The record goes in the DQ file at §391.51(b)(4). It is also your early-warning system: lines 7 and 9 of the automatic failures are about what this record would have told you — a suspended license, a disqualification.

Duty 2 — review it, and write the note (§391.25(b))

At least once every 12 months, review the record and determine whether the driver still meets the minimum requirements for safe operation and is not disqualified under §391.15. Then note it: a dated record of the review naming who reviewed it, kept in the file at §391.51(b)(5), retained 3 years.

The pull without the note is the classic half-duty. The auditor's question is never "did a record arrive?" — it is "show me where you read it and decided." A review note can be three honest lines. Its absence is indistinguishable from a review that never happened.

The paper that is NOT required anymore — the §391.27 list

Older checklists name a third annual paper: the driver's own signed list of his traffic violations (§391.27). FMCSA removed that requirement in 2022. The annual record pull replaced it — the state's record is a better witness than the driver's memory. Do not chase drivers for a form the rule no longer asks for, and treat any checklist that still lists it as what it is: stale. Preparing from a stale checklist cuts both ways — you collect papers nobody wants and miss the duties that actually changed, which is why every serious checklist carries a "rules checked" date.

Calendars are the compliance

Nothing about these duties is hard. Everything about them is forgettable — three papers, per driver, per year, on cycles that start on different hire dates. That is precisely the class of work the date checks in New Entrant Audit exist for: the annual record, the annual review note, and the annual Clearinghouse query each run on their own 12-month cycle per driver, and the page checks every one of those dates against today the moment you type it.

Questions, answered

Who am I allowed to order the MVR from?

The state agency, or a reporting service acting as your agent — ordered by you, with the driver's authorization where the state requires it. The record must be the state's, not the driver's screenshot of it.

I am the only driver. Do I review my own record?

Yes. The duties attach to the driver, and the owner-operator is a driver with a file like any other. Pull it, review it, note it, file it.

What date starts the 12-month cycle?

The duty runs every 12 months from the last performance — hire date for the first cycle. The safe practice is a company-wide annual pull month plus per-driver tracking for mid-year hires; the engine tracks the per-driver dates.