The FAA recently solicited comments on Form 8310-3, Application for Repair Station Certificate and/or Rating, as it seeks renewed approval from the Office of Management and Budget (OMB) to collect that information. ARSA submitted comments noting that the current form does not accurately reflect regulatory requirements applicable to the sale or transfer of repair station assets.

As provided in Title 14 of the Code of Federal Regulations (14 CFR) § 145.57(b): “if the holder of a repair station certificate sells or transfers its assets, the new owner must apply for an amended certificate in accordance with § 145.51.” However, verbiage in Form 8310-3 suggests that any change in ownershiprequires an amended certificate. This discrepancy between the rule and the Form creates confusion when an incorporated repair station merely transfers stock, not assets. Section 145.57(b) does not apply to such transactions.

ARSA therefore suggested the Form be changed to state “Sale or Transfer of Assets” instead of “Change in Ownership”. The Association also recommended that the FAA clarify differences between a stock and asset transfer, and provide a statement regarding the inapplicability of § 145.57(b) to company stock transactions, in the pertinent section of Order 8900.1.

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