Compliance FAQ
What is the difference between a process agent (BOC-3) and a BMC-91 filing?
BOC-3 is the process-agent designation under 49 CFR §366 - names someone authorized to accept legal service of process in each state. BMC-91 is the financial-responsibility filing under 49 CFR §387 - confirms the carrier has the required BIPD insurance coverage on file. Both are required before FMCSA operating authority activates, but they cover completely different requirements.
Reviewed by Korey Sharp-Paar · Updated
Why does it matter?
The 49 CFR §366 process-agent regulation (BOC-3) and the 49 CFR §387 financial-responsibility regulation (BMC-91) are separate federal requirements that both gate authority activation. BOC-3 is administrative - the carrier names a registered agent in each state to receive legal documents. BMC-91 is substantive - the carrier's insurance provider confirms that the §387.9 BIPD coverage is in effect.
A new MC application has three federal items that must clear before authority activates: (1) the application itself, (2) the BOC-3 process-agent designation, and (3) the BMC-91 financial-responsibility filing. All three are required; missing any one of them keeps the authority in PENDING status indefinitely. Filing the BOC-3 and BMC-91 early keeps them comfortably inside the 20-day deadline that runs from the FMCSA Register notice, so they aren't what the grant waits on.
BOC-3 is filed by a registered process-agent provider (someone with current FMCSA blanket-agent standing) on the carrier's behalf. BMC-91 is filed by the carrier's insurance provider (someone authorized to file federal financial-responsibility evidence) on the carrier's behalf. Carriers don't file either one directly; both are intermediated by a qualified third party.
The two filings meet in FMCSA's records (Motus public search), which show BOC-3 status and BMC-91 status as separate items. Brokers vetting the carrier check both - a carrier with BOC-3 on file but BMC-91 missing is not legally authorized to operate even though the MC number itself is issued. Most brokers run both checks before adding a carrier to the approved list.
Start your USDOT and MC authority application
We prepare your USDOT number and MC operating-authority application; it is submitted to FMCSA in Motus by you or a filer you authorize. FMCSA charges a $300 application fee for each operating authority type (49 CFR 360.3T); a USDOT number is free. Our $199 service fee and the $300 FMCSA fee are itemized as two separate amounts before you pay ($499 total).
Submitted to FMCSA in Motus by you or a filer you authorize.
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