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FAA “Legal Name Match” and TSA Rules for CFIs

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After all the expense and time spent on checkride preparation and arranging the elusive DPE (with good weather and airplane), the #1 cause of disappointing checkrides is the lack of a legal name match on the documents. (We discussed the endorsements and experience in a previous blog).  This problem starts on day one, when the eager aviation learner is directed to IACRA (usually without guidance) to apply for their student pilot certificate. Without guidance, the newbie enters whatever name they feel works. This very first entry into IACRA sets the stage for failure. After all the money is spent and the immense amount of study and practice, this simple lack of care and attention to details torpedoes a flight test. The FAA requires an *EXACT* name match on all required documents (and the knowledge test)!

Match the Initial Student Application to their Passport!

Since the knowledge test now is registered through IACRA, the primary source of checkride name problems usually comes from the student certificate compared with the “legal government document.” Every CFI with a new learner must very carefully supervise the applicant’s first entry into IACRA. The CFI should ensure this matches the applicant’s passport (if they have one). Increasingly, as states move to “REAL ID” that meets federal I-9 requirements, the licenses will often change with renewal to match the passport (full name, no middle initials).

The medical certificate often has a mismatch on the name since this data is entered on a separate website FAA Medxpress. A DPE can accept a discrepancy here and complete the flight test, but the applicant is required to immediately call the FAA medical office (405-954-4822) and get an updated (name match) medical. If you notice *yours* does not match, make the call and fix it now.

TSA Rules Require CFI Registration

The new TSA rules went into effect last fall. These provided considerable relief for foreign students training in the US; primarily a longer training window and the ability to change flight training providers. The TSA also announced some ambiguous requirements for CFIs regarding TSA registration. The FAA finally stepped in last week and clarified the requirements with a bulletin on faasafety.gov. Every active CFI (with the apparent exception of employees of a “registered provider”) is required to create an account with the TSA now (even if you only train US citizens). There is an exception for flight review/IPCs but any “new” training requires registration. The process is fairly simple. (If you register as an individual CFI you are automatically established as the “Provider Administrator” and “Security Coordinator” of your account). This little TSA Provider Guide is very helpful.

This FREE King School course also covers the details. If you are trying to read though this rule, please understand the term “Candidate”  § 1552.3, defines a “candidate” as anyone applying for flight training who is neither a U.S. citizen nor a foreign military pilot endorsed by the DoD.” Candidates are not US citizens.

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If a flight school (not the FAA definition; could be part 61 or a club) has a “Flight Training Provider” account, this seems to relieve the individual CFIs of the burden of registration with the TSA (not a lawyer folks). This paragraph seems to indicate that these instructors are listed as part of the program? But then the TSA definitions page defining “flight training provider” seems to indicate *every* CFI must register (simple process) AOPA’s article trying to explain the TSA maze of regulations.

More MOSAIC

MOSAIC in Sept. “SAFE Strategies!”

We discussed the ramifications of MOSAIC for pilots and especially CFIs in last week’s blog. The SAFE Strategies on Sept. 1st will include a complete review of this new expansion of Sport Pilot privileges. Register here to receive that important digital news magazine. Fly safely (and often)!


Join SAFE and get great benefits. You get 1/3 off ForeFlight and your membership supports our mission of increasing aviation safety by promoting excellence in education.  Our FREE SAFE Toolkit App puts required pilot endorsements and experience requirements right on your smartphone and facilitates CFI+DPE teamwork. Our CFI insurance was developed by SAFE specifically for CFIs (and is the best value in the business).  10 Tools for New CFIs Here

2 responses to “FAA “Legal Name Match” and TSA Rules for CFIs”

  1. Steve Avatar
    Steve

    re: “Every active CFI is required to create an account with the TSA now” I believe this is slightly incorrect. Every “flight training provider” is required to have an account. Per our flight school’s FAA POI, a flight school is a single flight training provider, not the individual CFIs so as individual CFIs operating only under the flight school’s umbrella, we do not need an FTSP account.

    1. David St. George Avatar
      David St. George

      The FAA has absolutely no authority over the TSA process (often frustrated by it), but you are correct that 141 schools handle the screening and validation of foreign students. Whether you are required, as individual CFIs to create an account, I could not determine from reading the rule as published. ((I am not a lawyer so I follow the FAA/AOPA interpretation. This paragraph seems to indicate this “umbrella status” exists for “schools” if a Flight Training Provider account exists for an organization.

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