When Do CMV Regulations Apply? A vehicle is generally considered a Commercial Motor Vehicle (CMV) when it: • Is used in commerce (including transfers between dealership locations), and • Has a Gross Vehicle Weight Rating (GVWR) of 10,001 pounds or more If both conditions are met, federal CMV requirements apply, even for internal dealership transfers. What Is Required for Compliance? When CMV regulations apply, both driver and vehicle requirements must be met. Driver Requirements • Valid driver’s license (CDL required only at 26,001+ lbs.) • DOT medical certificate (medical card) • Compliance with Hours of Service (HOS) (often satisfied via timecards) • Driver Qualification File maintained by the employer Vehicle Requirements • Display of a USDOT number • Annual DOT inspection documentation • Properly functioning safety equipment (brakes, lights, tires, mirrors) • Emergency warning triangles • Fire extinguisher Do You Need a USDOT Number? If your dealership is operating CMVs in interstate commerce, a USDOT number is generally required. Dealers have two options: • Company-wide USDOT number: centralized recordkeeping • Separate USDOT numbers per location: each store manages its own compliance The best approach depends on how your operations are structured. Note: Not all locations require a USDOT number. If a dealership does not transport vehicles over 10,000 pounds (and does not otherwise meet CMV thresholds), it may not be necessary. Recordkeeping Considerations Obtaining a USDOT number triggers federal recordkeeping requirements. • Records must be maintained at a designated location • Driver time records (Hours of Service) must be accessible • Centralized recordkeeping may not be practical for multi-state operations USDOT Number Display Requirements Vehicles operating as CMVs must display: • Company name (exactly as registered) • USDOT number UNDERSTANDING USDOT and CMV Requirements for Dealership Vehicle Transfers BY JAY O’LEARY Government Relations & Compliance Specialist, NHADA 8
RkJQdWJsaXNoZXIy MTg3NDExNQ==