You have finally closed on the purchase of your aircraft. Questions will arise later but you forgot what your lawyer said and you do not want to sort through all those e-mails. This is your “cheat-sheet” to answer your questions that will arise after closing.
Your Aircraft Registration Has an Expiration Date
Your aircraft registration must be renewed every three (effective as of 1/23/2023 it is now seven years) years. Pay attention to your snail-mail because the security code that allows you to do the simple on-line renewal is on the notice of expiration.
The Address on your FAA Registration Application is Important
The address on your registration application will be used by the FAA for important correspondence. If you used an address that no-one ever checks or which would require someone to forward your mail and you never confirmed that they will forward your mail, you have some follow-up to do.
Your Entity’s International Registry (IR) Registration Expires
Your entity became registered on the International Registry when you purchased your aircraft and you received notice after 1 year that your status is about to become inactive and expire if you do not renew. You may not need to renew if you do not have any planned purchases, sales or financings pending. However, have you checked your financing documents to make sure that you are not obligated to be continuously registered on the International Registry?
The FAA Expects to be Notified of Changes in your LLC
You changed the member or manager of your limited liability company that owns your aircraft so you now need to amend your LLC Statement in Support and file the amended document with the FAA.
Even Though You Renewed Your Aircraft Registration, Other Actions You Took Invalidated Your Aircraft Registration
If you make a change to the ownership or management of the entity that owns your aircraft or any other entity in the chain of ownership (yes, even 7 steps removed from the aircraft), that structure change may have invalidated your aircraft registration. The FAA has a specific definition of U.S. Citizen and there are specific definitions for individuals, partnerships, corporations, and limited liability companies. If the person who wants to make the change tells you “we do this all the time, it can’t possibly affect the aircraft”, you should check with someone who knows the ins and outs of the FAA’s definitions regarding who can own an aircraft. You may be surprised that your planned change would mean that the aircraft registration would be invalidated because the entity would not fit within the FAA’s definition of U.S. U.S. Citizen.
When You Sell, Return Your Original Registration to the FAA
When you sell your aircraft, the permanent registration should be removed and the registered owner (Seller) must complete and sign the back and send it to the FAA. The instructions and address are on the back of the permanent registration.
Melissa K. Gowin is a Senior Legal Assistant with the aviation law firm of Jetstream Aviation Law, P.A. and assists attorneys, clients and escrow agents in coordinating documentation for complex aircraft purchase, sale and financing transactions. Jetstream Aviation Law can be found at www.jetstreamlaw.com. Melissa K. Gowin (mgowin@jetstreamlaw.com)
The information provided here is not legal advice and does not purport to be a substitute for advice of counsel on any specific matter. For legal advice, you should consult with an attorney concerning your specific situation.
