LODA for aircraft owned by an LLC Flying Club
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My flying club has an experimental aircraft and it's registered in an LLC.  Who is listed as the owner when applying for a LODA to train in the aircraft?  Is it the LLC or does every member of the Flying Club need to get their own LODA for the aircraft?

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The policy notification speaks only of individuals giving/receiving training. As such, I think each individual member receiving, and each individual CFI giving, training would need their own individual LODA. Further, based on the court case which triggered the new policy, because the LLC as a corporate entity owns the plane (rather than the plane being co-owned by the members with all member's names on the registration), I'm not at all sure it's legal for the club as a corporate entity to rent the EXP plane to the individual members.  I suggest you have your club's legal counsel discuss the entire situation with the FAA Regional Counsel as a hypothetical before you go further or even continue renting the plane to members.

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CFI and owner do not each have to hold a LODA, just one or the other.  If the aircraft is owned by an entity, like an LLC, the FAA only needs one “primary” named on the LODA with their pilot certificate #.  Only one owner in the group needs a LODA.  That named owner can “delegate” the authority of the LODA to any one of the others.  The delegate is still required to comply with the conditions of the LODA.  

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Ruprecht At AOPA: 
 

CFI and owner do not each have to hold a LODA, just one or the other.  If the aircraft is owned by an entity, like an LLC, the FAA only needs one “primary” named on the LODA with their pilot certificate #.  Only one owner in the group needs a LODA.  That named owner can “delegate” the authority of the LODA to any one of the others.  The delegate is still required to comply with the conditions of the LODA.  

That is contrary to the policy as I read it. They were very clear when I spoke with them about the need for both the owner receiving the training and the instructor giving it to each have their trainee/instructor LODA.  Can you point to the language in the policy which supports your statements?

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Clarification I received by email from FAA's Brad Palmer- Manager, General Aviation and Commercial Division.

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Share it with us? And did the Chief Counsel also sign it?  Remember, the old revoked policy came from Flight Standards, too.

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