Understanding Commercial Auto Insurance Filings

Operating a commercial trucking business requires adherence to specific insurance filing requirements at both federal and state levels. These mandatory insurance filings serve as proof that your business maintains adequate coverage to operate legally. At Cogo Insurance, we specialize in helping trucking companies navigate these complex requirements.

Federal Truck Filings and Forms

BMC-91X Filings

A BMC-91X filing is submitted to the Federal Motor Carrier Safety Administration (FMCSA) and certifies that you maintain sufficient liability insurance to cover the risks associated with transporting goods or passengers across state lines. This filing is specifically required when your insurance is provided by multiple companies rather than a single carrier.

MCS-90 Endorsement

The MCS-90 endorsement must be attached to your liability insurance and cargo liability insurance policies when federal filings are required. This endorsement guarantees minimum protection for the public in accidents where you’re legally responsible. While the MCS-90 itself isn’t filed with the FMCSA, the BMC-91X filing serves as certification that the MCS-90 endorsement has been issued.

Unified Carrier Registration (UCR)

The Unified Carrier Registration Plan replaced the Single State Registration System in 2007. This streamlined system allows interstate motor carriers, brokers, freight forwarders, and leasing companies to submit financial responsibility information and registration fees to a single state.

Under the UCR Plan:

• Motor carriers conducting interstate operations must register in a base state
• Your base state is where the largest number of your vehicles will operate
• Currently, 41 states participate in the UCR Plan
• Private and exempt carriers must register under the UCR Plan
• Registration fees are shared between all states in which you operate

The UCR Plan doesn’t affect intrastate trucking regulations within individual states.

Intrastate Truck Filings

Form E Filing

A Form E filing certifies that your liability insurance complies with your state’s financial responsibility laws. This form is submitted to the regulatory department in your business’s home state that oversees intrastate trucking.

Form F Filing

A Form F filing is an endorsement that adjusts your policy to conform to each state’s financial responsibility laws.

Form H Filing

A Form H filing guarantees your state that you maintain sufficient cargo liability insurance. This filing is submitted to the appropriate state department in your business’s home state, though availability varies by state and situation.

Form K Filing

A Form K filing is used to cancel a previous state filing and is submitted to the state agency that regulates motor carrier financial responsibility in your business’s home state.

State-Specific Truck Filings

Beyond the UCR, many states impose additional filing requirements for specific business types or vehicle categories operating within their borders. These filings are typically submitted to your state’s department of motor vehicles or other regulatory agencies.

California Filings

• CA OL 207: California Driving School Certificate verifying proof of insurance for driving schools
• MCP-65/HQMCP65: Certificate of insurance required for commercial vehicle operators in California who must obtain a Motor Carrier Permit and Carrier Identification Number
• PL914 Filing: Required for businesses offering commercial balloon, river rafting, or commercial skiing (class C) excursions

Colorado Filings

• Form 14: Required for towing businesses in Colorado, guaranteeing sufficient liability coverage for potential accidents while operating tow trucks

Connecticut Filings

• R1325C Filing: Required before obtaining a license to operate a leased or rented vehicle in Connecticut

Montana Filings

• HQMV-5 Filing: Certificate of insurance for towing businesses in Montana, guaranteeing sufficient liability coverage for tow truck operations

Ohio Filings

• OS-32 Filing: Guarantees sufficient liability insurance for accidents potentially caused by operating oversized vehicles or trailers in Ohio

Oklahoma Filings

• OK Form WA: Required for towing businesses in Oklahoma, confirming adequate liability insurance for tow truck operations

Rhode Island Filings

• GU1338C Filing: Verifies proof of financial responsibility or liability insurance in Rhode Island (vehicle-specific and requires special approval)

Texas Filings

• Form T: Required for towing businesses in Texas with a Vehicle Storage Facility (VSF) number

Driver Filings

SR-22 Filing

An SR-22 filing is a financial responsibility form submitted to your state’s motor vehicle department. It serves as proof of minimum liability insurance coverage and guarantees notification to the DMV if coverage lapses. This filing is typically required to reinstate a driver’s license after suspension.

SR-26 Filing

An SR-26 filing informs the DMV that an SR-22 has lapsed, expired, or been canceled.

Form FR-44

Verification of higher limits required after convictions for certain offenses, including DUI. The FR-44 must be maintained throughout the driver’s license suspension period.

Form FR-46

Form submitted by the insurance company to cancel an FR-44.

Certificates of Insurance (COI)

Similar to filings, certificates of insurance provide proof of financial responsibility by demonstrating adequate coverage:

• Oversized/Overweight Vehicles COI: Required in Alabama, Arkansas, Louisiana, Mississippi, and Pennsylvania for oversized or overweight vehicles and loads
• Florida DMV COI: Required for all commercial trucks and tractors with a gross vehicle weight exceeding 26,000 pounds in Florida
• DMV REG 1323 (California only): Certificate reporting primary liability, excess liability, commercial general liability, and umbrella liability coverages for private passenger carriers

How Cogo Insurance Can Help

Navigating the complex world of commercial truck insurance filings can be overwhelming. At Cogo Insurance, our specialists understand the intricacies of federal and state requirements and can help ensure your business remains compliant. Whether you’re an interstate carrier needing federal filings or a local operation requiring state-specific documentation, we have the expertise to guide you through the process.

Frequently Asked Questions (FAQ)

What is the difference between a BMC-91X filing and an MCS-90 endorsement?

A BMC-91X filing is submitted to the FMCSA as proof of adequate liability insurance when coverage is provided by multiple companies. The MCS-90 endorsement is attached to your policy and guarantees minimum public protection for accidents where you’re legally responsible.

Do I need both federal and state filings for my trucking business?

If you operate across state lines (interstate commerce), you’ll need federal filings. If you operate within a single state (intrastate commerce), you’ll need state-specific filings. Some businesses require both types depending on their operations.

What happens if I fail to maintain the required insurance filings?

Failing to maintain proper insurance filings can result in significant penalties, including suspension of operating authority, vehicle impoundment, and substantial fines. Your business may be forced to cease operations until compliance is restored.

How do I know which filings are required for my specific trucking operation?

The filings required depend on several factors, including your operating authority, types of cargo transported, vehicle weight, and the states in which you operate. Cogo Insurance specialists can assess your specific situation and determine all necessary filings.

How quickly can insurance filings be processed?

Processing times vary by filing type and regulatory agency. Federal filings typically take 1-3 business days, while state filings may take 3-10 business days. Electronic filings generally process faster than paper submissions.

If I change insurance providers, do I need new filings?

Yes. When changing insurance providers, new filings must be submitted to show proof of continuous coverage. Your previous insurer will typically submit cancellation notices (like Form K or SR-26), while your new insurer submits the replacement filings.

What’s the difference between UCR registration and insurance filings?

The Unified Carrier Registration (UCR) is a fee-based registration system for interstate carriers. Insurance filings (like BMC-91X or Form E) are separate requirements that prove you maintain adequate insurance coverage. Both are typically necessary for interstate operations.