Change of Registration Mark

During an aircraft acquisition, we encountered an unusual issue that we had not come across in our practice before: the FAA registration mark listed on the title report didn’t match the mark painted on the aircraft. Upon investigation, we discovered the seller had initiated a tail number change with the FAA but failed to complete the process.

The FAA’s process for changing an aircraft’s registration mark is time-consuming. After filing the request, it can take several weeks to receive authorisation. Once approved, the owner has one year to complete the change by signing and returning the FAA’s authorisation form, after which a new registration certificate is issued.

In this case, the owner received authorisation and painted the new mark on the aircraft, but failed to sign and return the form — resulting in the change not being finalised. After a year had lapsed, the FAA unassigned the number, leaving the aircraft without valid registration. The result of this was that the aircraft could not legally be operated.

To resolve this, we explored two options: (1) fast-track FAA approval to reassign the mark, or (2) revert to the previous registration. The first proved unviable, so the seller applied a vinyl overlay of the original mark and completed the required restrapping.

The problem was a novel one, but thankfully, it was also fairly easy to resolve. It served as a reminder that even the smallest things, especially those we often take for granted, should always be double-checked.

Matthew Potts
Partner