Do I need new BMC-91 for reinstatement?
Yes if the original BMC-91 has been canceled or non-renewed. The reinstatement filing requires active BMC-91 (or BMC-91X) insurance on file with FMCSA before the authority can be reactivated. New insurance has to be bound and the new insurer has to file BMC-91 electronically through FMCSA L&I before our reinstatement filing can succeed.
49 CFR Part 387 requires active BMC-91 insurance for any operating authority. When the authority is suspended or revoked for insurance lapse, the underlying insurance has to be replaced before reinstatement.
The flow: carrier secures new commercial-auto liability coverage from a new (or returning) insurer. The insurer files BMC-91 electronically through FMCSA L&I — typically same business day. We file the reinstatement on top once the new BMC-91 is reflected in L&I. Total typical reactivation: 24-48 hours from when new insurance is bound.
For carriers reinstating after a non-insurance-related suspension (audit failure, OOS order), the original BMC-91 may still be valid if the policy was kept current during the suspension. Verify in SAFER that BMC-91 is still active before relying on it; refile if it lapsed during the suspension period.
BMC-91X (auto liability only, no cargo) is acceptable for property carriers that don't need cargo coverage on the FMCSA filing — typically because cargo coverage is held separately or the carrier qualifies for an exemption. Most property carriers file BMC-91 (combined auto + cargo).