Do I need an MVR for a non-CDL driver?

The §391 driver-qualification regulations apply to any "commercial motor vehicle" as defined in 49 CFR §390.5 - which is broader than the §383 CDL threshold. A 14,001-lb GVWR straight truck running interstate is a CMV under §390.5 even though the driver doesn't need a CDL to operate it. The §391.23 pre-employment investigation requires an MVR on that driver just like the CDL driver next door.

For a non-CDL CMV driver, the §391.23 screening stack is: (1) state MVR per §391.23(a) for every state where the driver held a license during the prior 3 years, (2) the §391.23(a)(2) previous-employer inquiry for safety-performance history, and (3) PSP if the carrier wants the federal roadside-inspection layer. PSP covers any CMV inspection, not just CDL-eligible ones, so it remains useful even when CDLIS and the Clearinghouse drop out.

CDLIS is irrelevant for a driver who has never held a CDL - the AAMVA pointer database only contains CDL-event records, so a query on a non-CDL driver returns empty. The §382 Clearinghouse query is also out of scope; the Clearinghouse rule (49 CFR Part 382, Subpart G) was written specifically for CDL drivers subject to the §382 drug-and-alcohol testing program.

If the same carrier hires both CDL and non-CDL CMV drivers, the cleanest pattern is two intake workflows: the CDL stack adds CDLIS and the §382.701 query on top of the non-CDL baseline. The DQ file requirements under §391.51 are the same for both - the file just has fewer items in the non-CDL workflow.