TSA rule - registration of freelance instructors

Dylan Smith wrote in message ...

And how are they defining courses of instruction? Does a BFR count as
something that has to be registered - considering the student will be
PIC and is already rated? What about checkout flights if you're a
foreigner going to a new FBO?

I'm actually surprised there isn't a discussion going on w.r.t. the rule's
interpretation. (AOPA's web has a letter on it their General Counsel wrote
TSA asking for some clarifications.) Here's my layman's interpretation:
flight instruction - anything done with an instructor in an airplane or
simulator (doesn't say you have to go flying, but does exclude
"ground instruction")
course of instruction - not really defined in the 44 page document as I recall,
but the registration web site requires you specify a flight training
provider from the list and specify a start and end date, when you register
for "flight training"

Also, in the section that calculates cost, it assume a Candidate will register,
on average, twice a year.

So, I'd say, as it stands, every BFR requires a registration.

Oh, and although AOPA has asked for a clarification on this one, at this point
"recurrent training" is defined (on pg. 12) as training required for employees
of commercial operators or private business aircraft ops, so things like BFRs,
(the T-6 refresher I'm planning in Nov. etc) are all Category 3 (everything
else in aircraft 12,500lbs gross) and require registrations each time.
(You only have to do the fingerprinting the first time, it notes they'll keep
them on file. You do pay the $130 each registration, though.)

If I had known I was going to have to do all this for 3 flights in a T-6,
I wouldn't have bothered, but now that I've booked the flights and the plane
ticket to FL, I'm doing the whole sheebang, rick