DQ File Transfer in Carrier Acquisition / Merger

When a carrier acquires another carrier, the driver qualification files transfer with the driver. The acquiring carrier inherits responsibility for verifying records.

Permitted transfer methods

1. Original files transferred physically (or digitally) at acquisition
2. Acquired carrier provides documents for the acquiring carrier to create new DQFs

The acquiring carrier becomes responsible from the acquisition date forward. Prior period responsibility stays with the prior carrier's records.

Required verification by acquiring carrier

• All 12 documents present (per § 391.51)
• Documents are current (not expired)
• Documents are properly executed (signatures, dates)
• Driver's safety performance history covers the acquiring period if needed

Common gaps in inherited DQFs

• Missing prior-employer inquiries for older hires
• Missing road test certificates for drivers hired before § 391.31 was clarified
• Medical examiner verification missing for pre-2014 drivers (National Registry didn't exist)
• ELDT certificates missing for drivers with CDLs predating 2/7/2022 (exempt — note in file)

Inheriting non-DOT drivers

If acquiring a carrier with both DOT and non-DOT drivers (e.g., property-only intrastate), only the DOT-qualified drivers need DQFs under federal rules. State rules may differ.

Reporting obligations

• Acquiring carrier inherits the prior carrier's DataQ-eligible inspection history
• Acquiring carrier inherits CSA score (50% of acquired carrier's score weight typically merges per FMCSA SMS rules)
• File FMCSA Form MCS-150 within 30 days of acquisition

Remediation steps for incomplete DQFs

• Document the gap (note "inherited file — document not available from acquired carrier")
• Re-create what you can (re-pull MVRs, re-do prior employer inquiries)
• Update medical exam if current cert has passed
• The acquiring carrier cannot be cited for the prior carrier's documentation gaps, but YOU must remediate from date of acquisition forward

Best practice

Audit each acquired DQF within 60 days of acquisition. Set up the acquired carrier's drivers in your Compass DQ Files module — Compass scans for missing slots and surfaces remediation actions.

CFR citations

• 49 CFR § 391.51
• 49 CFR § 390.21

How Compass surfaces this

This skill is searchable in Compass Ask and runs against the carrier's actual fleet data when invoked from the relevant tracker. Read-only; no actions taken without explicit user approval.

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