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Indefinite Complaint Regulatory Suspensions


To protect public safety on the highways, the Massachusetts Registry of Motor Vehicles strives to maintain accurate and complete records for drivers who operate in Massachusetts, both residents and non-residents.

The Registry, on a continuous basis, reviews its records to locate possible multiple or duplicate driving records. When duplicate or multiple records are found, the Registry merges them so as to maintain a single, accurate record for each individual operator. One record allows accurate record sharing with other agencies, including law enforcement and allows the Registry to revoke or suspend a license based on complete records.

The Registry has been merging large numbers of driving records. The RMV has been finding records with “A” numbers, which are record numbers assigned to a person who commits a motor vehicle infraction in Massachusetts who does not have a Massachusetts Driver’s License at the time. The RMV is merging the records with these “A” numbers with other records which have “S” or “SA” numbers.

As part of the record merger process, if there are outstanding obligations such as unpaid citations, or the merger of the records will trigger a new obligation such as the ignition interlock device requirement, the Registry will send a letter to the record holder instructing him or her to schedule an administrative hearing. If the customer fails to schedule the hearing within the allotted timeframe, the Registry will automatically impose a complaint regulatory license suspension.

The purpose of an indefinite complaint regulatory license suspension is to force the customer to schedule a hearing so that a Registry Hearing Officer can inform him or her of some outstanding obligation or a requirement that must be satisfied.

The merger of driver records will generate an ignition interlock device (IID) requirement if the license holder is reinstating from a DUI suspension and he or she has multiple DUI convictions.

In addition to a “complaint regulatory” notice, the merger of accounts may also generate an indefinite immediate threat suspension if the combined records warrant a conclusion that the driver constitutes an immediate threat to public safety.

Resolving complaint regulatory license suspensions can be simple or complex, depending on the contents of the records and the underlying facts of the case.

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