David Megginson wrote:

wrote:

Following is the only reference I could find to the subject in the FAQs to which
you referred. I agree with the following language and it is quite different
than the BS you got from the Seattle FSDO. FSDOs are so often full of it.

ANSWER: Ref. § 61.57(d); If you’re intending to serve as the pilot in command
during the instrument proficiency check (and in most cases the flight instructor
is always considered to be the pilot in command on a flight where flight
training/checking is being provided) and you intend to file an IFR flight plan,
regardless whether the flight is in VMC or IMC, you must be instrument current
in accordance with § 61.57(c). As per § 61.57(c), “. . . no person may act as
pilot in command under IFR or in weather conditions less than minimum prescribed
for VFR, unless . . .”

Sounds like pretty-much the same thing the Seattle FSDO said -- anyone can
file an IFR flight plan in the U.S., but only an instrument-rated, current
pilot may fly it (in IMC *or* VMC). Since there's no point filing a flight
plan that you cannot legally use, that seems to settle the point.

Upon re-reading the FSDO stuff, you're right. I misread it the first time.