Splitting hairs on the ASA aircraft registration

My view from the sideline:

American School of Aviation, Inc. is a California corporation with its president and other corporate officer(s) are not U.S. citizen.

Title 14 CFR Part 47 of the Federal Aviation Regulations (FAR) governs the requirement related to the civil aircraft registration in the US

Part 47.3 stipulates Registration required.
Part 47.5 defines Applicants.
Part 47.7 defines U.S. citizens and resident aliens with respect to civil aircraft registration.
Part 47.9 defines “Corporations not U.S. citizen”.
Part 47.9(f) stipulates thrice annual report requirement by the registrant to the FAA.

All ASA aircraft (30 in all) are currently registered under FAR Part 47.7 and issued aircraft registration certificate bearing “Corporation” instead of its true and factual status of its corporate entity as “Foreign Corporation”.
In the FAA AC Form 8050-1 Aircraft Registration Application, there is a specific box to be checked off for Non-citizen Corporation and provided along with “Certification” section for the applicant’s certification for a non-citizen corporation. If these sections were properly completed in the ASA aircraft registration application, all of its registration then should have been issued under Part 47.9 with the respective registration certificate bearing ”Foreign corporation”

If ASA has made erroneous entry in its aircraft registration application and submitted to the FAA Aircraft Registry knowingly or not knowingly and obtained its registration certificates, then all of the ASA aircraft are not registered under Part 47.9 and not in compliance with Part 47.9(f) requirement. This ipso facto invalidates all of its registrations under FAR 47.41(a) (ii) and requires ASA to surrender all of its invalidated registration certificate in accordance with FAR 47.43 (b).

All ASA aircraft are to be grounded immediately if its current registration is found to be invalid on the foregoing premise stated. Aircraft operation without having required documents on board, aircraft registration certificate is one of among them is a Federal code violation subject to FAA enforcement action including an imposition of a civil penalty for each and every violations committed. If you fly twice with an invalid registration, that’s two counts of violation and the flight log and pilot’s logbook to show that for the record easily later on. If any of the ASA students are still flying the ASA airplane, you should think twice before stepping into the plane next time.

Well, it sure beats me why this fundamental infraction of the FAR evaded the FAA inspector’s repeated scrutiny for so long. I guess sometimes things can be seen better when you step back a little and observe them from distance. The old saying “. Don’t Miss the Forest for the Trees.” rings so true here.

I could see things pretty well from where I stand in the sideline.
Till next time,

Echo Yankee, over & out!

Dan Winther
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