The Federal Aviation Administration (FAA) recently announced that it has made further changes to its document filing processes in order to help limit the transmission of COVID-19. These new processes are developing daily and we remain in close contact with the FAA to confirm the changes detailed below first hand.
Hard copy documents received by the FAA will now be "quarantined" for at least 72 hours. Hard copy documents include both those documents (1) sent in by mail or courier; and (2) deposited in the delivery bins at the now-shuttered FAA registration window. Additionally, FAA processing times will likely extend beyond 72 hours, possibly as long as five to seven days, due to reductions in FAA staff. If your aviation transaction requires original blue ink signatures, then you will need to deliver those documents to the FAA significantly ahead of closing in order to allow for the extended FAA processing timeline. This extended processing timeline will also cause delays in International Registry filings.
While a postal carrier or courier can confirm receipt and delivery of mailed documents, and your escrow agent can confirm placement of a filing packet into an FAA delivery bin, the FAA will still need to process the documents in order to provide an FAA filing time. However, under FAA rules an aircraft may fly in the U.S. on a properly filled out, signed, dated duplicate copy of the FAA Registration Application that has been mailed or delivered to the FAA until receipt of the hard card, subject to general restrictions, including without limitation, financing requirements and restrictions on international travel.
Please also note that FAA processing delays are likely to continue for the foreseeable future, as the FAA continues to work to protect its employees. The FAA may even mandate that all but essential employees stay home, meaning those employees required to keep our nation's air system open. In the event that further FAA staff reductions occur, the document processing timeline may be extended further.
The FAA has provided a portal for the submission of electronic documents, subject to the following requirements:
While the FAA will issue an email receipt when it receives documents submitted electronically, this will not be the FAA filing time. Receipt of the filing time will still come after the FAA processes the documents. While the FAA reduction in workforce will still affect the processing time, the processing time for electronically submitted documents may be faster than it is for hard copy documents because electronic documents will not be subject to the mandatory quarantine period. While electronic submittal of documents may help expedite the issuance of fly wires, in comparison to hard copy document submittal, we can no longer expect same-day issuance of fly wires.
We will continue to keep you informed of further changes and our aviation team is here to help you construct creative solutions in these challenging times.
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