What changed
An MVR shows only what the State of record has posted at the time of the pull. An MVR pulled before a suspension or an out-of-state conviction is posted will look clean even though the driver should be flagged. Federal rules give a State 10 days from a conviction to notify the licensing State of an out-of-state CDL holder's traffic conviction through CDLIS (49 CFR 384.209(c)), so a later pull may show events an earlier one missed.
How to handle the lag
The annual inquiry under 49 CFR §391.25(a) must go to each licensing authority where the driver held a CMV operator's license or permit during the preceding 12 months - for a driver who changed State of license in that period, that means both the old and new States. The carrier must also review the record and keep a note of who reviewed it and when in the DQ file (§391.25(b)-(c)).
The pre-employment inquiry under §391.23(a)(1) is due within 30 days of the date employment begins and goes to every State where the driver held a license or permit in the preceding 3 years. The inquiry must be made in the form and manner each State prescribes (§391.23(b)).
When to use third-party MVR services
Third-party MVR services are convenient because they handle multi-state pulls in a single transaction. Ask any vendor whether it retrieves the record from the State at the time of your order, and check the record date on each report.
For situations where MVR freshness matters (pre-dispatch verification of a driver returning from a suspended period), pull directly from the state DMV.
What to do next
Audit your MVR pulls. Confirm pulls are happening at hire and annually thereafter. Document the source (direct state vs third-party aggregator). Our /guides/eldt-cdl-training-requirements page covers MVR-related driver-fitness rules.
Sources: 49 CFR 391.23: https://www.ecfr.gov/current/title-49/section-391.23 ; 49 CFR 391.25: https://www.ecfr.gov/current/title-49/section-391.25