Federal Register / Vol. 89, No. 33 / Friday, February 16, 2024 / Notices 12413 

charge) before signing the lease 

purchase agreement? Did you have a 

clear picture of your responsibility in 

the case of a major mechanical 

breakdown of the CMV? 

5. Were you able to negotiate the 

terms? Were you provided any 

information about other financing 

alternatives? Did other drivers have a 

different set of options and if so, why? 

6. Were you informed of how the 

motor carrier works with independent 

contractors vs. company drivers and 

lease-purchase drivers when business is 

slow? Are you treated similarly or is 

there a difference between the 

assignment of loads, etc.? 

7. Please elaborate on any additional 

restrictions placed on your use of the 

CMV or additional financial agreements 

imposed outside of the written lease 

agreement. Did they encompass takehome pay, driver access to loads, etc.? 

8. Please elaborate on any additional 

financial products associated with your 

work as a CMV lessee (e.g., training 

debt, maintenance debt, earned wage 

access, contact from debt collectors, 

etc.). For instance, if you took out 

maintenance debt, were you required to 

use the title of your CMV as security? 

9. Were you able to successfully 

complete the terms of your leasepurchase agreement? If you did not 

complete your lease, why? How much 

did you owe at the completion of your 

lease? Were any charges assessed related 

solely to your lease payment or were 

there other charges, such as repayment 

of a maintenance bill or loan? If there 

were other charges, please explain. 

10. If you owe a balance on your 

lease-purchase agreement, are you being 

contacted by the motor carrier, thirdparty debt collectors, or finance 

companies? Are there processes, 

policies, and procedures for taking and 

handling disputes about the debt? Has 

information about your debt been 

furnished to credit reporting companies 

or employment screening companies? 

Have you been threatened with a 

lawsuit to collect these debts? Do 

collection efforts cease when a driver 

files for bankruptcy or obtains 

bankruptcy discharge? 

11. How did your expectations about 

the benefits of the lease compare to the 

reality of working under that lease? 

What have the effects of your leasepurchase agreement been on your 

finances, employment experience, 

professional mobility, workplace health 

and safety, and family’s well-being? 

Lessors of CMVs 

1. If you are or were a lessor of CMVs, 

what best practices do, or did you 

implement or recommend to ensure that 

all leases of CMVs you provide are fair 

and just? Do you underwrite leases? If 

so, how? How do you determine the 

value of a CMV and the expected 

depreciation? If your lessees are pleased 

with the terms you provide, please 

expound on those terms. 

2. If you lease CMVs to drivers but do 

not own the CMV (e.g., the CMV is 

being financed by your company and 

then you lease it to a driver), how do 

you determine how much to charge the 

driver under the lease agreement and 

how do you ensure the driver can 

ultimately own the vehicle if there is a 

lease-purchase agreement? 

3. Do you have any specific 

agreements available to drayage drivers 

at ports relating to the Clean Truck 

Program or any similar program to 

decrease emissions from port 

operations? Do you have any data that 

would show the impact of truck leasing 

agreements on the net compensation of 

CMV drivers, including port drayage 

drivers? 

Sue Lawless, 

Acting Deputy Administrator. 

[FR Doc. 2024–03205 Filed 2–15–24; 8:45 am] 

BILLING CODE 4910–EX–P 

DEPARTMENT OF TRANSPORTATION 

Federal Motor Carrier Safety 

Administration 

[Docket No. FMCSA–2023–0172] 

Agency Information Collection 

Activities; Approval of a New 

Information Collection Request: Impact 

of Driver Detention Time on Safety and 

Operations 

AGENCY: Federal Motor Carrier Safety 

Administration (FMCSA), Department 

of Transportation (DOT). 

ACTION: Notice and request for 

comments. 

SUMMARY: In accordance with the 

Paperwork Reduction Act of 1995, 

FMCSA announces its plan to submit 

the Information Collection Request (ICR) 

described below to the Office of 

Management and Budget (OMB) for 

review and approval. 

This notice invites comments on a 

proposed information collection titled 

Impact of Driver Detention Time on 

Safety and Operations. This research 

study will collect data on commercial 

motor vehicle (CMV) driver detention 

time representative of the major 

segments of the motor carrier industry, 

analyze that data to determine the 

frequency and severity of detention 

time, and assess the utility of existing 

intelligent transportation systems (ITS) 

solutions to measure detention time. 

Approximately 80 carriers and 2,500 

CMV drivers will provide data in the 

study. The study will provide a better 

understanding of the impact of driver 

detention time on driver safety and 

CMV operations and inform strategies 

that may be used to mitigate driver 

detention time. The number of public 

comments received in response to the 

60-day FR notice was 171. 

DATES: Comments on this notice must be 

received on or before March 18, 2024. 

ADDRESSES: Written comments and 

recommendations for the proposed 

information collection should be sent 

within 30 days of publication of this 

notice to www.reginfo.gov/public/do/ 

PRAMain. Find this information 

collection by selecting ‘‘Currently under 

30-day Review—Open for Public 

Comments’’ or by using the search 

function. 

FOR FURTHER INFORMATION CONTACT: Dan 

Britton, Mathematical Statistician, 

Office of Research and Registration, 

DOT, FMCSA, 6th Floor, West Building, 

1200 New Jersey Avenue SE, 

Washington, DC 20590–0001; 202–366– 

9980; dan.britton@dot.gov. 

SUPPLEMENTARY INFORMATION: 

Title: Impact of Driver Detention Time 

on Safety and Operations. 

OMB Control Number: 2126–00XX. 

Type of Request: New ICR. 

Respondents: CMV carriers and 

drivers. 

Estimated Number of Respondents: 80 

CMV carriers and 2,500 CMV drivers. 

Estimated Time per Response: 30 

seconds (for drivers and CMV carrier 

operation team). 

Expiration Date: This is a new ICR. 

Frequency of Response: Once per 

delivery/pick-up. 

Estimated Total Annual Burden: 

7,869.17 hours. 

Background 

‘‘Detention time’’ refers to the extra 

time CMV operators wait at shipping 

and receiving facilities due to delays not 

associated with the loading and 

unloading of cargo. Drivers are often not 

paid for this extra time. Although there 

is currently no standard definition of 

detention time, the CMV industry, the 

U.S. Government, and academic 

researchers in the United States have 

previously used dwell time—the total 

amount of time spent at a facility— 

exceeding 2 hours to define when 

detention time occurs. 

Detention time in the CMV industry is 

a longstanding issue and consistently 

ranks as one of the top problems for a 

large portion of CMV operators on an 


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ongoing basis. Further, detention time 

often results in lost revenue for many 

drivers and carriers. Reducing detention 

time may reduce costs for carriers, 

increase pay for drivers, and improve 

CMV drivers’ ability to make deliveries 

on time or arrive at a destination as 

planned without violating hours of 

service (HOS) requirements. Finally, 

drivers who experience less detention 

time may be more likely to drive safely 

to reach their destinations within the 

HOS limits and less likely to operate 

beyond HOS limits and improperly log 

their driving and duty time to make 

deliveries on time. 

An important first step in addressing 

detention time is understanding the 

factors that contribute to the issue. 

FMCSA completed a study in 2014 on 

the impact of detention time on CMV 

safety. Although this study provided 

valuable initial insights, it had several 

limitations, including a small sample of 

mostly large carriers, a rudimentary 

estimation of detention time, the 

inability to identify time spent loading/ 

unloading, and data that did not cover 

an entire 12-month period. Therefore, 

FMCSA needs additional data from a 

broader sample of carriers to understand 

the safety and operational impact of 

detention time, to better understand 

why detention time occurs, and to 

identify potential mitigation strategies 

the CMV industry may use to reduce 

detention time while improving 

operational efficiencies and safety. 

The purpose of obtaining data in this 

study is to evaluate the impact of driver 

detention time on safety and CMV 

operations. Specifically, there are three 

primary objectives for the data 

collection in this study: (1) assess the 

frequency and severity of driver 

detention time using data that represent 

the major segments of the motor carrier 

industry; (2) assess the utility of existing 

ITS solutions to measure detention time; 

and (3) prepare a final report that 

summarizes the findings, answers the 

research questions, and offers strategies 

to reduce detention time. Completing 

these research objectives will provide 

insight into any relationship between 

driver detention time and CMV safety. 

Additionally, the findings from this 

study can contribute to a more complete 

understanding of these issues and 

facilitate private sector decisions that 

lead to reductions in detention time and 

improvements in safety and supply 

chain efficiency. 

The study includes data collection via 

electronic logging devices (ELDs), 

transportation management systems 

(TMS), vehicle telematic systems, safety 

records, and answers to questions 

delivered through the carriers’ 

dispatching systems. The ELD, TMS, 

telematics, and safety data are already 

collected by carriers. The only 

additional data that will be collected 

will be the answers to questions 

submitted through the carriers’ 

dispatching systems. This information 

will allow FMCSA to identify the 

severity and frequency of detention 

time, the factors that contribute to 

detention time, and the administrative, 

operational, and safety outcomes of 

detention time. After agreeing to 

participate in the study, carriers will 

collect and provide 12 months of data. 

The carriers will be selected so that 

the sample is representative of the 

nation. Carriers will be selected from 

those who use an ELD, TMS, and 

telematics device or app that is 

integrated with the research team’s data 

collection system for delivery/pickup 

details, telematics and vehicle tracking 

metrics, and ELD data. However, the 

study may include other carriers that 

express interest in participating if they 

use an ELD, TMS, and telematics device 

that can be integrated with the research 

team’s system to collect data. These data 

are critical to answer the research 

questions. The final sample from this 

source will include up to 80 carriers 

with up to 2,500 total vehicles. This 

sample will include a variety of carrier 

operations, including long haul/short 

haul, private/company fleets and forhire fleets, port servicing (primarily 

chassis), owner-operators, hourly and 

mileage-based operators, truckload/lessthan-truckload, and dedicated local 

delivery. These carriers will range in 

size from single-vehicle owner-operators 

to carriers with hundreds of trucks, with 

a likely average fleet size of 

approximately 30 vehicles. Multiple 

analyses will be performed, including 

assessing the relationships between 

detention time and characteristics of 

carriers, facility locations, and driver 

schedules (appointment times, time of 

day, day of week, month, and season). 

Measures of detention time will include 

the number of detained stops per shift 

and the duration of each detention. 

Regression models will be used to 

compare these variables for significant 

differences in associated detention time. 

Another analysis will examine the 

relationship between detention time and 

safety outcomes during the shifts 

following the detention time. The 

relationships between detention time 

and safety outcomes will be evaluated 

by generalized linear models such as 

Poisson or negative binomial regression 

models. The independent variables will 

be the characteristics of detention time, 

such as detention time per shift. The 

response variable will be the number of 

safety outcomes (e.g., crashes) that 

occurred during the subsequent shift. 

The driving time will be treated as an 

exposure variable to normalize crash 

risk with respect to driving time. 

Finally, the study will estimate the 

cost per year associated with detention 

time, including lost productivity, 

disruptions to the supply chain, and any 

increases in fatal, injury, and propertydamage-only crashes. 

FMCSA published the 60-day Federal 

Register notice on August 24, 2023, and 

the comment period closed on October 

24, 2023 (88 FR 58060). A total of 171 

comments were received from the 

public. These comments revolved 

around 11 issues, with many comments 

covering more than one issue, to varying 

degrees: (1) the relationship between 

detention time and driver 

compensation; (2) organizational issues 

at the shipper/receiver, carrier, and/or 

broker; (3) the relationship between 

detention time and pick-up/delivery 

appointment times; (4) examples of 

detention time characteristics as 

experienced by commenters; (5) the 

relationship between detention time and 

HOS regulations; (6) the impact of 

detention time on logistics and the 

economy; (7) the impact of detention 

time on driver welfare; (8) the impact of 

detention time on driver and roadway 

user safety; (9) suggestions and support 

for detention time-related regulations; 

(10) considerations for defining and 

quantifying detention time and 

collecting necessary data; and (11) 

general support for the study. Responses 

to these issues are provided below. 

Many comments touched on multiple 

issues; however, the responses below 

are organized based on the primary 

feedback provided. 

The Relationship between Detention 

Time and Driver Compensation 

Two-thirds of the comments 

described a relationship between 

detention time and driver 

compensation. The comments included 

descriptions of current pay structures, 

including driver pay modality (i.e., pay 

by mile, load, or hour) and detentionspecific compensation (e.g., pay per 

detainment, maximum pay, proportion 

of detainment-related pay received by 

driver, etc.). The comments reflected 

hypotheses that current pay structures 

impact detention frequency and severity 

and that detention frequency and 

severity, in turn, also affect driver 

compensation. Several comments also 

included proposed compensation 

approaches to address detention 

frequency and severity and the resulting 

financial impacts on drivers. 


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Federal Register / Vol. 89, No. 33 / Friday, February 16, 2024 / Notices 12415 

FMCSA believes it is important to 

understand the relationship between 

driver compensation and detention 

time. An assessment of driver 

compensation and safety and other 

driver-related factors (including 

detention time) is the focus of a separate 

study sponsored by FMCSA and 

conducted by the Transportation 

Research Board. The study outlined in 

this notice is focused on the 

relationship between driver detention 

time, safety, and operations. FMCSA 

believes these studies will complement 

each other and provide vital information 

on detention time. 

Organizational Issues at The Shipper/ 

Receiver, Carrier, and/or Broker 

A total of 78 comments described 

organizational issues at the shipper/ 

receiver, carrier, and/or broker level and 

their impacts on detention time. These 

comments included inefficiencies at 

shippers/receivers that increase 

detention time (e.g., understaffed 

shipper/receiver facilities leading to 

backups in loading/unloading; difficult 

driver check-in procedures adding to 

time spent at a facility; products being 

processed at loading, which extends the 

loading time; shippers/receivers not 

honoring appointment times; lack of 

room in storage facilities for products to 

be unloaded; appointment times 

scheduled for facility shift changes or 

breaks; and overloading the truck). 

Comments also described poor 

communication and unequal power 

dynamics between shippers/receivers, 

drivers, and carriers/brokers regarding 

expected loading/unloading times and 

detention times. Several comments 

described difficulties obtaining verified 

documentation of detention time due to 

complicated paperwork and concern for 

adding waiting time to have paperwork 

completed. A few comments touched on 

leased warehouses and the potential 

impact on detention time. 

These comments illustrate the need to 

collect data on loading/unloading time, 

active dwell time, and detention time. 

The study outlined in this notice will 

collect this data through multiple 

methods: driver self-report, TMS data 

(such as shipper/receiver, order pickup/delivery locations, appointment 

time, billed amount for detention time, 

etc.), and telematics/ELD data (such as 

latitude and longitude and duty status). 

In addition, analyses in the study will 

consider carrier fleet size, operation 

type, geographic location, time of year, 

facility type, and other key features to 

determine their impacts on detention 

time and safety. Some comments 

proposed solutions to reduce detention 

time, but the study will only collect data 

on detention time as it occurs, without 

attempting to determine the 

effectiveness of alternative methods of 

reducing detention time. 

The Relationship Between Detention 

Time and Pick-Up/Delivery 

Appointment Times 

A total of 27 comments touched on 

the relationship between detention time 

and pick-up/delivery appointment 

times. The comments included 

discussions of appointment times not 

being honored at pick-up/delivery 

locations, unrealistic scheduled 

appointment times, and the impact of 

detention time on the remaining pickup/delivery appointment times 

scheduled for the day or week. The 

study will collect data on appointment 

times (if applicable) through the 

carriers’ TMS. The data will be analyzed 

to assess whether detention time varies 

for pick-ups/deliveries with and 

without appointment times. 

Shared Examples of Detention Time 

Characteristics as Experienced by 

Commenters 

A total of 49 comments provided 

detailed examples of detention time as 

experienced by commenters, some 

describing typical situations, with 

others describing atypical but 

significant situations, including reports 

of detention time lasting 24 hours. The 

study will capture detention time 

reports from up to 2,500 drivers over a 

year of driving. The detention time data 

will be assessed to understand the full 

spectrum of detention time experienced 

by the participating carriers and drivers. 

The Relationship Between Detention 

Time and Hours-of-Service Regulations 

A total of 41 comments described the 

relationship between detention time and 

HOS regulations. At a high level, HOS 

regulations provide legal boundaries on 

daily and weekly driving and working 

hours. The comments described the 

difficulty in capturing detention time 

using standard HOS regulation duty 

statuses. When waiting at shippers/ 

receivers, drivers often need to remain 

vigilant for their opportunity to load/ 

unload, and they might use this time to 

perform non-driving work, which means 

they are not truly ‘‘off duty.’’ However, 

remaining ‘‘on duty’’ for detention time 

can use a significant portion of drivers’ 

regulated workday hours, limiting their 

opportunities to work or drive after they 

leave the shipper/receiver. After 

experiencing detention time, drivers 

also feel impacted by HOS limits when 

needing to drive to a safe resting 

location. Comments included 

discussion of falsifying logs after 

detention time. The study will capture 

information on drive time, work time, 

and HOS-related violations through ELD 

data and driver self-reports via 

prompted electronic questions. 

Additionally, the study will collect data 

on all activity while the vehicle is at a 

delivery/pickup location to account for 

drivers who go off-duty while detained. 

These data will provide a better 

understanding of the relationship 

detention time has with HOS 

regulations. 

Impact of Detention Time on Logistics 

and the Economy 

Ten comments discussed the impact 

of detention time on logistics and the 

economy. Previous studies have 

estimated the impacts of detention time 

on industry earnings and society as a 

whole. The comments explained that 

detention time causes supply chain 

issues, impacts efficiency, and reduces 

time available to make additional pickups and deliveries, and can reduce the 

quality of goods, leading to products 

being rejected by the receiver upon 

delivery. Additionally, drivers often use 

fuel while waiting to load/unload. The 

study outlined in this notice will 

investigate the costs of driver detention 

time in terms of lost productivity and 

disruptions to the supply chain. 

The Impact of Detention Time on Driver 

Welfare 

There were 66 comments that 

discussed the impact of detention time 

on driver welfare. Drivers who 

experience detention time may find 

themselves unexpectedly needing to 

complete their route at night. 

Commenters reported not being allowed 

to rest while waiting to load/unload and 

not being allowed to rest at the shipper/ 

receiver after detention time, forcing 

them to return to the roadway to find 

safe parking. Commenters mentioned 

that drivers are often not granted access 

to essential facilities, such as restrooms 

or vending machines (possibly as a 

coronavirus disease mitigation strategy), 

and yet they also cannot leave the 

shipper/receiver without risking their 

place in line. For all these reasons, 

detention time can increase fatigue and 

cause stress, frustration, and anger. 

Several comments discussed the Fair 

Labor Standards Act (FLSA), which 

regulates minimum wage and overtime 

pay for private and government 

employees. Drivers are exempt from 

FLSA laws. The impact of detention 

time on driver welfare, while outside 

the scope of the current study, is an 

important topic and may be examined 

in a follow-up study. 


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12416 Federal Register / Vol. 89, No. 33 / Friday, February 16, 2024 / Notices 

The Impact of Detention Time on Driver 

and Roadway User Safety 

A total of 73 comments discussed the 

impact of detention time on driver and 

roadway user safety. After experiencing 

detention time, drivers may be inclined 

to drive aggressively and/or over the 

speed limits to stay within their HOS 

regulatory limits, arrive at the next 

appointment on time, or return home. 

The comments described how detention 

time can lead to fatigued driving, 

driving during hours outside a driver’s 

regular schedule (such as at night), 

unpredictable sleep schedules, and road 

rage. 

The study will capture information on 

safety-related events through insurance 

claims data, Federal crash data, 

telematics data, and driver self-reports 

via prompted electronic questions. The 

study will link the safety-related event 

data to detention time data and assess 

whether driver detention influences the 

likelihood of crashes and fatigue. 

Suggestions and Support for Detention 

Time-Related Regulations 

A total of 41 comments provided 

suggestions and/or support for detention 

time-related regulations, including 

potential regulations addressing driver 

pay, use of appointment times versus 

open pick-up/delivery windows, 

shipper/receiver facility maintenance 

and upgrades to improve efficiency, the 

use of leased warehouses, 

standardization of detention time 

documentation on pick-up/deliveryrelated paperwork, the FLSA, 

reasonable wait times, fines for 

shippers/receivers who go beyond a 

federally established wait time limit, 

and the creation of a Federal and/or 

publicly-accessible database that 

documents shipper/receiver detention 

time behavior. FMCSA believes the 

study outlined in this notice is essential 

to obtaining a full and updated 

understanding of detention time, which 

will help identify solutions to the 

problem. 

Considerations for Defining and 

Quantifying Detention Time and 

Collecting Necessary Data 

Five comments raised concerns 

regarding how to define detention time, 

accurately quantify detention time 

according to a standard definition, and 

collect the necessary data to conduct the 

study analyses. The definition of 

detention time has varied across 

industry, government, and research; 

however, it generally includes 

components regarding the time the 

driver has been at the shipper/receiver, 

the duty status of the driver, and 

loading/unloading progress. The 

comments emphasized that the study 

needs to collect accurate data. The 

current study will collect detention time 

data through multiple methods: driver 

self-report, TMS data (such as shipper/ 

receiver, order pick-up/delivery 

locations, appointment times, scheduled 

and planned arrival and departure 

times, billed amounts for detention 

time, etc.), and telematics/ELD data 

(such as latitude and longitude). The 

study will use GPS data and geofenced 

shipper/receiver facility data to obtain 

arrival and departure information. 

One comment suggested broadening 

the sample universe to include more 

than one telematics service in FMCSA’s 

carrier eligibility requirements. The 

comment also suggested expanding the 

sample universe to include carriers who 

do not use telematics services or ELDs. 

To collect the necessary data and 

answer the study research questions, 

carriers must use a telematics and ELD 

service. Since the 60-day Federal 

Register notice, FMCSA has partnered 

with one of the leading TMS, ELD, and 

telematics providers used by many 

small carriers. While the Agency may 

focus recruitment on clients of this 

service provider, the study documents 

have been revised to allow carriers 

using a different provider to participate 

if they meet the criteria and can 

integrate their platforms with the new 

technology provider. 

Another comment emphasized the 

need to protect personal information 

shared by carriers and drivers in the 

study. Protecting participant data is of 

the utmost importance to FMCSA. The 

Agency will take all the necessary 

precautions to ensure the confidentiality 

of participant data. As part of this 

process, all drivers and carriers will be 

assigned anonymous identification 

numbers to link all datasets. Further, 

FMCSA will scrub all datasets of any 

information that could potentially 

identify participants. Identifying driver 

and carrier information will not be 

shared with the Agency. 

One comment suggested the burden 

estimate was too low. However, the data 

management and cleaning tasks the 

commenter felt had not been accounted 

for will not be the responsibility of 

participating carriers. FMCSA will 

perform the additional data linking and 

cleaning tasks not included in the 

burden estimate. However, the Agency 

has removed the data collection task 

that asked carriers’ operation teams to 

respond to questions each time an order 

is booked, scheduled, or dispatched. 

Information that would have been 

collected by these questions was 

determined to be redundant to 

information collected via the automated 

data collection system, and using the 

automated data collection system to 

collect this information will reduce the 

burden on participating carriers. 

Support for the Study 

Thirteen comments specifically 

mentioned support for the study. The 

comments expressed the importance of 

collecting accurate and representative 

data, highlighting how updated 

detention time assessments could be 

utilized to address the frequency and 

severity of detention time. FMCSA 

believes this is an important study that 

will provide a critical and updated 

understanding of detention time across 

various segments of the industry. 

Public Comments Invited: You are 

asked to comment on any aspect of this 

information collection, including: (1) 

whether the proposed collection is 

necessary for the performance of 

FMCSA’s functions; (2) the accuracy of 

the estimated burden; (3) ways for 

FMCSA to enhance the quality, 

usefulness, and clarity of the collected 

information; and (4) ways that the 

burden could be minimized without 

reducing the quality of the collected 

information. 

Issued under the authority of 49 CFR 1.87. 

Thomas P. Keane, 

Associate Administrator, Office of Research 

and Registration. 

[FR Doc. 2024–03256 Filed 2–15–24; 8:45 am] 

BILLING CODE 4910–EX–P 

DEPARTMENT OF TRANSPORTATION 

Federal Motor Carrier Safety 

Administration 

[Docket No. FMCSA–2023–0265] 

Agency Information Collection 

Activities; Revision of an Approved 

Information Collection: Application for 

Certificate of Registration for Foreign 

Motor Carriers and Foreign Motor 

Private Carriers 

AGENCY: Federal Motor Carrier Safety 

Administration (FMCSA), Department 

of Transportation (DOT). 

ACTION: Notice and request for 

comments. 

SUMMARY: In accordance with the 

Paperwork Reduction Act of 1995, 

FMCSA announces its plan to submit 

the Information Collection Request (ICR) 

described below to the Office of 

Management and Budget (OMB) for its 

review and approval and invites public 

comment. FMCSA requests approval to 

renew the ICR titled, ‘‘Application for 

Certificate of Registration for Foreign 


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