Federal insurance filings for commercial motor carriers

The federal floor is a filing requirement

For most for-hire interstate property carriers, 49 CFR 387.9 sets a minimum public-liability filing of $750,000. Hazardous-materials operations sit higher, often $1 million or $5 million depending on the material. Passenger carriers have their own schedule. These figures are the amounts that must be on file with FMCSA, not a prediction of what a particular policy will pay on a particular claim.

The form you will see most often is BMC-91X, a bodily-injury and property-damage endorsement filed by the insurer. Cargo filings (BMC-34) are a different coverage and a much smaller number. A $5,000 cargo filing is not liability coverage for people in other vehicles.

Filing, policy, and MCS-90 are three different things

The Motus insurance dataset shows what was filed: insurer name, form, class (primary or excess), and the limit on the filing. The actual policy may have a different limit, deductibles, exclusions, and a list of covered autos. MCS-90 is an endorsement that can make the insurer responsible for a public-liability judgment even when the policy would otherwise deny the claim. It is not extra insurance sitting on top of the filing.

Describe the Motus row as the federal insurance filing as of the date you pulled it, not as money that will be paid on a claim. If Motus has no row, the census snapshot may still show a bipd-on-file amount from QCMobile. That census field can lag the Motus cutover. Cite both, and date both.

State minimums can be higher, and excess layers exist

Some states require higher liability limits for certain operations. Large fleets often carry excess or umbrella layers that never appear in the FMCSA file. The federal record is the floor that was filed, not the ceiling of every policy the company bought. The preservation letter should go to the insurer named on the filing anyway, because that is the company FMCSA has on record.