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10 Answers

IFR currency expiration after getting CFII

Asked by: 5190 views FAA Regulations, Flight Instructor, Instrument Rating

I’m just trying to figure out exactly when my IFR currency expires. I did my CFII checkride on 5/17/2019. But my actual certificate has an issue date of 6/11/2019. So the question is would I go six months out from May or June? My guess is probably from May. But if it’s from June then hey it gives me another month! The reason I ask is because I’ve been only doing flights with student pilots, so I haven’t able to get any approaches in. 

Thanks

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10 Answers



  1. Kris Kortokrax on Sep 14, 2019

    What is the regulatory basis for counting a practical test for issuance of a Flight Instructor Instrument as an IPC?

    There is explicit language in 61.56(d)(2) that allows one to use a practical test for a Flight Instructor certificate or added rating to the Flight Instructor certificate as a Flight Review.

    The exceptions to the requirement for 61.57 are outlined in 61.57(e). There are exceptions to 61.57(c) for 121 and 135 pilots. There is no exception for completion of a CFII practical test.

    There is a legal interpretation dealing with the fact that a practical test for the Instrument rating on a pilot certificate counts as an IPC because the pilot has demonstrated proficiency.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2008/Wynne%20-%20(2008)%20Legal%20Interpretation.pdf

    During the CFII practical, the applicant typically is demonstrating his ability to teach. This would involve evaluating the examiner’s (student’s) performance of the maneuvers. The applicant may be asked to demonstrate some of the maneuvers, but that would not be sufficient to meet the requirements for an IPC as outlined in the ACS.

    I see one other problem. If your CFII ride was completed on May 17th, why would your certificate have an issuance date of June 11th?

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  2. KDS on Sep 14, 2019

    I want to expand on one thing Kris wrote. There is no valid reason that I can think of why the date of issue on your certificate should be other than the date of the completion of your practical test. Something is not right somewhere.

    I strongly recommend that you first get your temporary certificate in hand and check the date of issue on it. Then contact the FAA’s Airman Registry Branch at:

    (866) 878-2498 or (405) 954-3261

    Give them all of the information and let them know about the disconnect. They will guide you from that point.

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  3. Mark Kolber on Sep 15, 2019

    Agreed that earning an instrument rating on an *instructor* certificate (not a *pilot* certificate) does not reset the instrument currency clock.

    I’m not concerned with the piece of plastic “issue” date so long as the CFI expiration date is correct.

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  4. KDS on Sep 15, 2019

    I agree with Mark and I wouldn’t lose sleep over it either. I’m also of the school that says if something is wrong that can be fixed, then fix it. However, he also raises an excellent point along the way. What is the date of expiration on your new plastic CFI certificate? Is it May 31, 2021 or June 30, 2021 or something else?

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  5. Kris Kortokrax on Sep 15, 2019

    The expiration date will be keyed to the certificate date. The only possible explanation would be that the poster completed an end of course test under Part 141 on May 17th and the certificate was not processed by an ACR until June 11th.

    He would perceive the end of course test as the practical test, but he might not have received a graduation certificate until later.

    It really is a big deal that the paperwork be done properly. Otherwise, it could present an issue under 61.59, although more of an issue for the DPE/ACR.

    As to his instrument currency, I would hope that his instructor made sure he was instrument current for the practical / end of course test. I can’t imagine an examiner not wanting to see a prospective CFII operate within the system and that would require instrument currency. He would need to look at the last time he did an IPC or was instrument current and work within that timeframe.

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  6. mbrugg on Sep 15, 2019

    Thank you all for your answers.

    I attended one of the biggest flight schools in the world. So, I think the reason why the issue date is almost a month later is because the records department gets backed up with all the paperwork processing through the FSDO.

    I was for sure current when doing the CFII checkride. I was doing up to 4 approaches and holding during each week prior.

    Also the expiration date of my newly issued CFI cert with the instrument rating is August 31, 2021.

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  7. Mark Kolber on Sep 15, 2019

    Actually, Kris, often enough the issue date of the plastic is not keyed to the date of the “checkride” or other qualification. And the expiration date might be unrelated to either.

    For example, my physical commercial pilot certificate “Date of Issue” is March 25, 2013.” I passed the checkride back in 1993. The 2013 days was after I sent in a change of address.

    My current CFI certificate “date of Issue” is 1/17/2019 (renewal course completed 4 days earlier) with an expiration date of 4/30/2021.

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  8. Kris Kortokrax on Sep 15, 2019

    How in the world did I forget about the 3 month window?

    Of course one would get to keep the current expiration month, if renewal is done within the preceding 3 calendar months. That would include renewal by practical test as in the poster’s case.

    If you were attending as school, such as UND (a Part 141 school), you would not have done a practical test. You would have done an end of course test conducted by a chief instructor, asst. chief instructor or check instructor. The school would issue a graduation certificate which could be used to meet the requirements for the certificate per 61.71. The date on your certificate would be the date you met the requirements by presenting the graduation certificate to an ACR.

    As far as currency, if you were current on May 17th and did nothing further, your currency would expire end of November 2019. (6 calendar months preceding the month of flight under IFR Counting backwards October, September, August, July, June, May). If your current school has an AATD or FTD (probably no FFS), you could maintain your currency in one of those devices.

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  9. KDS on Sep 15, 2019

    Ahhhhh! The school course logic makes perfect sense and it’s no doubt as Kris suggested.

    mbrugg, did you get a temporary CFI certificate (the white paper copy) at some point and if so, what was the date of issue on it?

    The date of issue does change as in Mark’s example of an address change with a request for a new certificate. It also changes if an airman loses their certificate and requests a new one. It also changes on something that requires an inspector’s review like a name change or even a sex change. (Before anyone wonders how that is accomplished, I’ll say the “review” is done on legal documents, not the airman) However, for practical tests, it should always be at the completion of the test.

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  10. Mark Kolber on Sep 16, 2019

    >>How in the world did I forget about the 3 month window?
    Old age? 😀

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