Does your Limo Company Need To Be registered With The DOT?
by Joe Guinn, Managing Partner at Limo & Bus Compliance
A Common Misconception
It is a common misconception that companies operating exclusively inside their state do not need an FMCSA Motor Carrier Number ( also known as an MC number) and only have to comply with state and local laws regarding buses, and larger vehicles.
This is simply not true.
DOT Number & MC Number
The Federal Motor Carrier Safety Administration (FMCSA) issues two numbers to companies engaging in commercial transportation. The first is the United States Department of Transportation, or DOT number. The DOT number serves as a unique identification number for all motor carriers for the purpose of collecting safety data, compliance information, and accident investigations.
The second is the FMCSA Motor Carrier, or MC number, often referred to as operating authority. An MC number is another unique number assigned to carriers that transport passengers in a commercial motor vehicle.
In this case, it applies to a vehicle built to hold nine or more people and used for compensation in interstate commerce.
You May Be Engaging in Interstate Commerce Without Realizing It
Most people think that interstate commerce means crossing state lines in the vehicle, but they’re wrong.
In May 2014, the FMCSA released an updated explanation to interstate commerce. The clarification explained that the airport is a port of entry for interstate cargo, mainly your passengers. That means that if you use a commercial motor vehicle (CMV) to pick up an out of state passenger, or accept bookings for a CMV from out of state affiliates, you are engaged in interstate commerce.
A commercial motor vehicle is considered any vehicle built to hold nine or more people and used for compensation in interstate commerce.
Here are some helpful links directly to the FMCSA website explaining this in more detail:
So what does all this mean?
This means that any limo company with a passenger van, 120” stretch limousine, sprinter, minibus, or any other vehicle with the capability of holding 8 passengers and a driver must be registered with the DOT and have an MC number.
This also means that each driver in your fleet must comply with federal law, and you as an owner must maintain vehicle and driver records as required by the FMCSA. These include complete driver qualification files, hours of service records, driver background checks, and records of vehicle maintenance. This also means that you can be selected for roadside inspections or for a full DOT audit at any time.
Where do I Start?
More helpful tips can also be found at dotbuscompliance.com or by calling Joe Guinn at (210) 259-7470.