§391.25(a) requires the carrier, at least once every 12 months, to make an inquiry to obtain the motor vehicle record of each driver covering the prior 12 months from every state in which the driver held a CDL or commercial learner's permit. §391.25(b) requires the carrier to review the MVR and consider any evidence of disqualification or §383.51 / §391.15 violations. §391.25(c)(2) requires a dated, signed note documenting the review.
What the review must consider
§391.25(b)(1) directs the carrier to consider whether the driver still meets minimum qualification standards under §391.11. §391.25(b)(2) lists disqualifying offenses — DUI, leaving the scene, felony involving a CMV, multiple serious traffic violations. The §391.25(c)(2) note documents that the consideration happened, not just that the MVR was pulled.
Severity weight
Severity weight 1 in the Driver Fitness BASIC. Individually a low-weight finding, but every driver missing an annual review is a separate cite — and a pattern is a §385.321(b)(1) audit auto-fail concern in the same way a missing DQF is.
How to prevent it
- The annual MVR is a 12-month cycle from the prior pull date, not a calendar-year deadline. Schedule it.
- Pull from every state where the driver held a CDL or CLP in the prior 12 months — a single-state pull misses out-of-state violations.
- The §391.25(c)(2) review note must be dated and signed by a person with authority to review (typically the safety director or DOT supervisor).
How Roadworthy HQ helps
Roadworthy HQ tracks annual_mvr_last_at and annual_mvr_next_due per driver, surfaces upcoming reviews on the dashboard, and captures the §391.25(c)(2) review event with manager attribution at the moment of upload — so the dated, signed review note is part of the DQF, not a separate piece of paper that lives in someone's drawer.