The final rule establishing the Unified Registration System has two effective dates. The first is November 1, 2013, which is when the Agency will begin enforcement provisions for failing to file biennial updates. It should be noted that federal regulations have always required carriers to update their registration information biennially, even before the Unified Registration System became finalized. November 1, 2013 is also when the prohibition on operating with an inactive USDOT number will take effect. All remaining URS requirements will become effective on October 23, 2015, to allow time for FMCSA to launch the website.
 

The new registration form that will be created as a result of the URS will be known as Form MCSA-1. FMCSA states that entities that already have a USDOT Number do not need to file the Form MCSA-1 until they need to update registration information. Additionally, the final rule states that "Beginning on November 1, 2013 (the compliance date of the revised biennial update provision), the Agency will issue a warning letter 30 days in advance of a biennial update deadline to notify the entity that its USDOT Number will be deactivated if it fails to comply with the biennial update requirement." FMCSA states in the final rule that the registration and biennial update requirements can be complied with by providing the information to a state in which the carrier registers its vehicles, as long as that state is a member of the Performance and Registration Information System Management (PRISM) Program, and has integrated the USDOT registration/update capability into its vehicle registration program. If the state does not meet the PRISM requirements, the carrier will need to complete such filing directly with FMCSA.
 

To see the complete text of the final rule announcing the URS, click here. For questions, contact TRALA's Joe Sculley at jsculley@trala.org or by calling (703) 299-9120.