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AC 61-65, A.42

Asked by: 1078 views ,
Flight Instructor, Instrument Rating

I am a CFI looking to get my CFII. Studying on my own, I prepared for and passed the FII (100%). As I look at the endorsements required to take the CFII checkride, I need A.1, A.2 (except I don't because I aced the knowledge test), A.42, and A.44. 

I have no questions about A.1, A.2, or A.44. A.42 is weird though. 61.183(f) requires me to pass a knowledge test appropriate to the instructor rating sought which is specified in 61.185(a)(3). 61.185(a)(3) requires me to receive and log ground training on the knowledge areas for an instrument rating. But there is no requirement that the training logged to satisfy 61.185(a)(3) occur before I pass the test required by 61.183(f). Yet, the text of A.42 in AC61-65 sound like it has to happen before the knowledge test because it ends with "...is prepared for the Flight Instructor Instrument knowledge test." 

Will the DPE care that A.42 in my logbook is dated a few weeks after the date I took the knowledge test?  

Also, as a related follow-up, I believe that any CFII can endorse me for this checkride regardless of how long they've been a CFI/CFII, right? The fact that I am not a first-time CFI candidate means that 61.195(h) doesn't apply, right?

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2 Answers



  1. Mark Kolber on Nov 10, 2022

    I don’t understand. How did you take a CFII knowledge test without the written authorization to take the test?

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  2. Bryan on Nov 10, 2022

    No written authorization is required to take the test per the FAA’s own testing matrix at https://www.faa.gov/training_testing/testing/media/testing_matrix.pdf, page 11. Authorization for FIH, FII, IHC, ICP, IEP, IFP, and IGI: Requires NO instructor endorsement or other form of written authorization.

    And the regs don’t require it either. Only the language of the endorsement in AC61-65 suggests it but it isn’t actually in the regs.

    When I did my CFI check ride I commented that no endorsement was required for the FIA to the DPE and she said there actually was. I didn’t argue because it was a check ride. But that same texting matrix (now page 10) says that no instructor endorsement is required for any flight or ground instructor test except AFA, AFG, GFA, and HFA.

    All of this is what brought me to this question. I cannot find anything in the regulations or the FAA testing matrix that requires an endorsement to take the test but the DPE’s comment on my CFI ride and the language of AC61-65 A.42 seem to suggest a phantom requirement. Did there used to be a requirement and they did away with it?

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