SBTC has reported various issues to SeikoSoft, the Unified Carrier Registration (UCR) Board's contracted technical agent, advising Canadian and Mexican domiciled agents cannot register because they do not possess American Tax ID Numbers.
SBTC further suggests the use of unverified Tax ID Numbers as passwords violate reasonable and customary password standards and protocols used by Federal & State Government agencies...
From:
"James Lamb" <james@truckers.com>
Date:
Thu, Jan 24, 2019 2:12 pm
To:
toby@seikosoft.com
Cc:
Avelino.Gutierrez@state.nm.us, jboppjr@aol.com, anarog@bopplaw.com, cyoungs@bopplaw.com, laurence.socci@influence-strategies.com, raymond.martinez@dot.gov, larry.minor@dot.gov, charles.fromm@dot.gov, rpschweitzer@rpslegal.com, woodchucklsg@hotmail.com, wiedies4@gmail.com, m.hoeme@kcc.state.ks.us, elizabeth.leaman@state.ma.us, larry.herold@state.co.us, cathy.gautreaux@dot.gov, carol.fallin@txdmv.gov, burroughs@tianet.org, sbowling@dor.IN.gov, adamanderson@utah.gov, scott.morris@psc.alabama.gov, rpitcher1040@gmail.com
Subject:
RE: Problem with last four digits of tax id
As we wait for a reply to the January 19th email below, we would like to offer additional information.
It has now come to our attention that Canadian and Mexican carriers cannot file for UCR due to the last tax id obstacle you have placed in front of them because they do not have American Tax ID Numbers.
They are expressing concern that they will be subjected to civil penalties once they enter the United States.
What would you and the Board like us to tell these carriers engaged in international/interstate commerce?
From: "James Lamb" <james@truckers.com>
Date: Sat, Jan 19, 2019 9:07 am
To: toby@seikosoft.com
Cc: Avelino.Gutierrez@state.nm.us, jboppjr@aol.com, anarog@bopplaw.com, cyoungs@bopplaw.com, laurence.socci@influence-strategies.com, raymond.martinez@dot.gov, larry.minor@dot.gov, charles.fromm@dot.gov, "rpschweitzer@rpslegal.com" <rpschweitzer@rpslegal.com>, "woodchucklsg@hotmail.com" <woodchucklsg@hotmail.com>, "wiedies4@gmail.com" <wiedies4@gmail.com>, "m.hoeme@kcc.state.ks.us" <m.hoeme@kcc.state.ks.us>, "elizabeth.leaman@state.ma.us" <elizabeth.leaman@state.ma.us>, "larry.herold@state.co.us" <larry.herold@state.co.us>, "cathy.gautreaux@dot.gov" <cathy.gautreaux@dot.gov>, "carol.fallin@txdmv.gov" <carol.fallin@txdmv.gov>, "burroughs@tianet.org" <burroughs@tianet.org>, "sbowling@dor.IN.gov" <sbowling@dor.IN.gov>, "adamanderson@utah.gov" <adamanderson@utah.gov>, "scott.morris@psc.alabama.gov" <scott.morris@psc.alabama.gov>, "rpitcher1040@gmail.com" <rpitcher1040@gmail.com>
Subject: Problem with last four digits of tax id
On behalf of the 15,000 members of the Small Business in Transportation Coalition (SBTC), I am writing to you to echo our concerns that we have already made to the FMCSA and the UCR Board about the implementation of the last 4 digits of motor carriers' tax ID number as a password to access their UCR record to tender payment and avoid civil penalties during enforcement.
As we understand it, you have programmed the ucr.gov website to require carriers to enter the same last four digits that have been entered on the most recent MCS-150. The problem with using this as your method of security is that carriers are not prompted to enter their tax ID on their MCS-150 twice as is standard and customary protocol followed by security professionals.
The attached snip from the URS system shows the tax ID is captured
only once
when a carrier registers online.
Furthermore, FMCSA has historically allowed carriers to apply for USDOT Numbers and revise their records through paper MCS-150 forms. In such cases, the carrier's principal, designee or agent manually writes the number on the form and then either FMCSA staff or outsourced contractor manually enters the number into FMCSA systems. Therefore there are at least two points of possible human error.
Generally, the US Dept. of Commerce's National Institute of Technology has issued a draft Guide to Enterprise Password Management.
But the page is down due to the Government Shutdown.
Since carriers have not had the opportunity during the initial registration process to verify their Tax ID twice, the data are likely faulty in many instances and your referral of carriers to their tax form or the IRS to acquire their tax ID number does not resolve the problem if your version of the tax id number is erroneous to begin with. We have received reports of many carriers being blocked because of a tax id mismatch, mostly from permitting company industry supplier members of the SBTC.
We have therefore asked FMCSA to direct the removal of the tax ID requirement as was the case for 11 years of the program when hosted by Indiana.
Sincerely,
James Lamb, president
SBTC
