AOPA Pilot Magazine - November 2019 - 108

NEWS & NOTES

PILOT PROTECTION SERVICES

What's your address?
FAA guidance for aircraft registration
MANY AIRCRAFT OWNERS CHOOSE

BY IAN ARENDT

Pilot Protection Services

to establish a legal entity such as a
trust, corporation, or limited liability
company to own their aircraft. While this
is ordinarily a perfectly legal arrangement,
the FAA recently issued an opinion letter on
the manner in which a trust should register
its aircraft. Specifically, the FAA has opined
that the trust may not utilize its registered
agent's address for aircraft registration purposes made pursuant to FAR 47.31 or 47.45
unless the owner trustee is also the registered agent. In arriving at this conclusion,
the FAA reasoned that a registered agent's
address is neither the mailing address of the
owner nor the physical address of the owner.

Therefore, a registration application utilizing
a registered agent's address "is not completed" under FAR 47.31(b)(1). Although the
letter specifically applies to aircraft owned
by a trust, the same reasoning may apply to
other legal entities. If the FAA discovers a
registered agent's address has been inappropriately utilized on a registration application,
it may deny the application.
Accordingly, in order to avoid time-consuming delays in registering your aircraft,
you must make certain the actual owner's

IAN ARENDT is an in-house attorney with

AOPA's Legal Services Plan, offered as part
of AOPA's Pilot Protection Services.

aopa.org/pps

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AOPA FINANCE |

Adam answers

address is included in the registration application. Further, if the owner's physical
address differs from the mailing address,
be certain to include the physical address
as well. Generally, we recommend utilizing
the legal entity's regular mailing address
and principal office address in completing
the aircraft registration application.
If you have any questions about aircraft
registration, call AOPA Legal Services at
800-872-2672.

The AOPA Credit Card provides:
BY ADAM MEREDITH
A O PA AV I AT I O N F I N A N C E

Q: What is the typical down payment percentage on a jet? Possibly a CJ3+?
A: How the aircraft is being used will be a primary factor in determining the
required down payment. For Part 91 personal/business use, lenders typically
will finance up to 85 percent of the purchase price or aircraft value, whichever is less. Part 135 charter or other commercial usage generally requires
larger down payments; 30 percent down is typical for this type of usage. How
the loan is structured can also play a factor in the down payment. Larger
down payments are typically required for these types of loan structures.

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CONTACT AOPA
ADDRESS CHANGE?

Send your new address and AOPA
membership number to AOPA:
421 Aviation Way
Frederick, Maryland 21701-4798
Fax: 301-695-2375
aopa.org
TOLL-FREE PILOT
INFORMATION CENTER

800-USA-AOPA (872-2672)
pilotassist@aopa.org

AOPA FOUNDATION

AOPA AIRCRAFT FINANCING

AOPA AIR SAFETY INSTITUTE

AOPA PERSONAL INSURANCE

AOPA CREDIT CARD PROGRAM

AOPA PILOT PROTECTION SERVICES

800-955-9115
aopafoundation.org
800-638-3101
airsafetyinstitute.org

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with the best card for pilots.
877-787-3171
aopa.org/creditcard

800-627-5263
aopafinance.com

800-USA-AOPA (872-2672)
aopa.org/membership/personal
800-USA-AOPA (872-2672)
aopa.org/pps
AOPA RENTAL CAR PROGRAM

aopa.org/cars

AOPA PILOT INFORMATION CENTER HOURS

Do you have questions or need information about an aviation topic? Access the team of aviation experts in our Pilot Information Center
during our convenient weekday hours. Call 800-USA-AOPA (872-2672) Monday through Friday, 8:30 a.m. until 6 p.m. Eastern time, with
your questions and our staff will be happy to assist you.
Visit the website (aopa.org/membership) to learn about upgrading to our higher levels of membership with Pilot Protection Services
coverage included.
108 | AOPA PILOT November 2019

http://www.aopa.org/pps http://www.aopafinance.com http://www.aopa.org/creditcard http://www.aopafoundation.org http://www.aopafinance.com http://www.airsafetyinstitute.org http://www.aopa.org/membership/personal http://www.aopa.org http://www.aopa.org/pps http://www.aopa.org/creditcard http://www.aopa.org/cars http://www.aopa.org/membership

AOPA Pilot Magazine - November 2019

Table of Contents for the Digital Edition of AOPA Pilot Magazine - November 2019