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Job 02 · Federal and state filings

// Trucking insurance agencies · The second job

Federal filing requests, compared with the policy and the carrier's record before anyone asks the insurer to file.

A carrier needs an MCS-90, a new authority needs a BMC-91X, or a state wants a Form E. Someone has to confirm the operating authority, the form called for, and that the legal name and limits match as written. A free AI proof of concept does that comparison on copies of 20 to 30 requests your desk already cleared, and lists every mismatch for your agent. Your reviewer, whoever on your staff knows filings best, marks each list against what actually happened.

Book a proof-of-concept call30 minutes with Rob
Past requests
20 to 30
Filings made
None
Who decides
Your licensed agent

// The one job

The request, the policy and the public record, side by side

Today a filing request comes from the carrier, from a new authority application, or from a state. Someone pulls the policy, looks up the carrier's USDOT and MC record, works out the operating authority and which form is called for, and reads the legal name and limits as written. Only when those line up does anyone ask the insurer to file.

In the proof of concept, AI reads the same request, the policy pages and a saved copy of the public record, then names the form called for and lists every mismatch it finds, field by field: legal name, DBA, docket number, limit, effective date. It sends nothing to an insurer, FMCSA or a state. Your reviewer compares each list with what your agent actually resolved.

Filing requestEmail, policy, public record
Carrier name
USDOT and MC
Form asked for
Effective
FieldRequestPolicy
Illustration, not a real filing
Compared
field by field
Mismatch listFor your agent
Form called for
Authority
Name as written
Limit as written
FieldPublic recordStatus
Illustration, field names only

// What makes it hard

A named form, a named carrier and a public record that all have to agree

An endorsement and a filing are different paper. The MCS-90 is attached to the policy and kept as proof at the motor carrier's principal place of business. The BMC-91 or BMC-91X is the certificate an insurer files with FMCSA. Section 387.311 ties the two together: the policy is amended by the right endorsement, and the certificate has to reflect it accurately. When a freight broker's onboarding desk asks for the MCS-90 filing, the draft says which of the two the request really needs.

The name has to be exactly the name. Section 387.15 has the endorsement issued in the exact name of the motor carrier, and certificates go in the full and correct name, with every partner named on a partnership. A change of legal name, trade name or business form has its own procedure under Part 365, on the Motor Carrier Records Change Form. So the draft lines up the policy's named insured, the legal name and DBA on the FMCSA record, and the name on the request. On the truck, the marking rule allows the legal name or a single trade name from the MCS-150, and when someone else's name appears the operating carrier's follows the words operated by. A door that reads differently is a question for your agent, not an automatic error.

FMCSA's layout leaves little room for guessing. The electronic record an insurer sends holds a filing type of BI&PD, cargo, bond or trust fund, an MC or FF docket number, a legal name up to 120 characters and a separate DBA up to 60, a form code, a full, primary or excess flag, the limit, the underlying limit, the effective date and the policy number. A BMC-91 stands for the full required limits while it remains in force. A BMC-91X can show full coverage or one layer, and a layered program needs a separate BMC-91X from each insurer, stating primary or excess with the underlying and maximum limits. The draft compares those fields with the policy, using the limit the rule requires, by name, rather than a figure of its own.

Some requests call for the wrong form. The motor carrier cargo filing in Part 387 is for household goods carriers, on a BMC-34 with a BMC-32 endorsement, so a shipper asking a general freight fleet for a federal cargo filing gets a question back, not a draft. Brokers file a surety bond or trust agreement on a BMC-84 or BMC-85, which is separate paper again. And FMCSA accepts a certificate only from an insurer authorized in the states the rule names, or eligible as a surplus lines insurer where the business is written, so the draft notes whose paper the policy is on for your agent to confirm.

States run their own clocks. Intrastate work brings Form E for liability and Form H for cargo, and the rules differ. Pennsylvania's Public Utility Commission says only insurance companies can provide those forms, a certificate of insurance is not binding, the binding proof has 60 days to arrive, and applications are dismissed when insurance agents don't arrange it in time. Texas calls for a new filing when a carrier changes insurers, changes its name, changes the classification of its cargo or replaces another active filing. Federal cancellation has its own timing: 35 days between insurer and carrier under section 387.7, and a filing that stands until 30 days after a BMC-35 reaches FMCSA. The draft notes which clock a change touches, and your agent decides. None of this is legal or coverage advice.

// What you send

Filing requests your desk already cleared

Copies only
No portal or FMCSA login
01

20 to 30 finished requests

The emails or forms asking for a federal or state filing, including a few that stalled or went back for correction. A new authority, a name change and a layered program are all worth having in the mix.

02

The policy pages behind them

Declarations, the named insured as written, the endorsement schedule and the limits, for each request in the sample.

03

The public record as you saw it

A saved copy of the carrier's USDOT and MC record from around the date of each request. FMCSA's record today may not match the record then, so the copy you kept is what makes the comparison fair.

04

What your agent did, NDA first

The message sent to the insurer, or the note on why a request waited. The NDA is signed before any of it moves, and nobody signs in to your agency management system, an insurer's portal or a live policy.

// Before it starts

Agreed before any request moves

Four decisions the owner makes up front.

Before the proof of conceptOwner's decisions
Reviewer
The owner's pick, often the agent or account manager who handles the most filings
Success criteria
Written first: which mismatches a list must catch, and when it must stop and ask
Sample
Your reviewer picks it, from finished trucking filing requests only
Price
The range for the live job

// How the test is judged

What your agent resolved, beside the list

Request by request
On the same 20 to 30 files
On the same 20 to 30 requestsWhat your agent resolvedThe draft list
Form called for, and the reasonMarked on your requestsMarked on your requests
Operating authority read correctly from the recordMarked on your requestsMarked on your requests
Named insured against legal name, DBA and requestMarked on your requestsMarked on your requests
Limits as written against the limit the rule requiresMarked on your requestsMarked on your requests
Primary or excess shown correctly on layered BMC-91X filingsMarked on your requestsMarked on your requests
State filings: which form, and what triggered itMarked on your requestsMarked on your requests
Requests held back for the agent, and whyMarked on your requestsMarked on your requests
No marks yet. Every cell stays empty until your own requests go through.Your reviewer decides what passes.

// After a yes

About 30 days on new filing requests

If your reviewer says yes, new filing requests get the same comparison for about 30 days.

Your licensed agent reads each list, resolves the mismatches with the carrier, and decides when to ask the insurer to file. The AI never contacts an insurer, FMCSA or a state.

The comparison keeps running on each new request, scored the way the test was. A second job is decided and priced by itself.

// Next, if you choose

What could follow the filing check

Ideas, ranked with you
Priced one by one
  1. 01

    Driver and unit schedule updates

    The fleet's list of added and deleted drivers and trucks compared with the current schedules, with a draft endorsement request for your account manager.

    Next
  2. 02

    Filing cancellation notices

    BMC-35 and state Form K notices matched to the policy and renewal dates, so your agent sees what is about to lapse.

    Then
  3. 03

    Broker and shipper certificates

    Certificate requests read against cargo limits and the units on the schedule, drafted for your staff to issue.

    After that

// One hard limit

Nothing gets filed. Nothing about coverage gets decided.

Your agency management system, an insurer's portal and every live policy stay out of this test, and nothing goes to FMCSA or a state. The test never binds, endorses or changes coverage, never decides what a policy covers, and files nothing at all. A licensed agent or account manager reads every list. Driver details that appear in a record stay out unless your reviewer agrees to redacted or look-alike copies. Commercial lines only. None of this is legal or coverage advice.

Priced per job. You get a range before the proof of concept and a fixed price before you sign.

Rob gives the range on the call, once he knows how many trucking accounts you write and roughly how many federal and state filing requests you clear in a month.

// Questions

What filing desks ask

Does anything get filed during the test?
No. Nothing goes to FMCSA, a state or an insurer. The draft is a list of mismatches and the form it believes is called for, and your agent decides what happens next.
Who actually files the BMC-91X?
The insurer. FMCSA has each insurer register to file these forms, so a filing comes from the insurer's account. The test only prepares your agent to ask the insurer with the right facts in hand.
Do you look up each carrier's record for us?
No. Your desk sends the copy of the record it saved at the time of each request, because today's public record may differ, and we don't run that search for you.
Do you handle state filings such as Form E?
They are in scope when your sample includes them. The draft notes which state filing applies and what triggered it, using the state rules your team works from, and your reviewer checks that against what your agent did.
Can your draft tell us which limit applies to a carrier?
It names the limit the rule requires for that kind of operation and compares it with the limits as written on the policy, but the call is your agent's. These pages describe a document test, not legal or coverage advice.
Rob Eason

Rob Eason, founder

// Book a proof of concept call

Your finished filing requests are the test.

A 30-minute call with Rob Eason, with a few questions first: your role, the trucking accounts you write, and roughly how many filing requests come in each month. Keep requests, policies and saved records with you until the NDA is signed.

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