LOAs · October 31, 2026 · 6 min read · By BizJetDocs

Buying an aircraft: which FAA authorizations don't transfer and what to reapply for

What a buyer must redo after closing: registration, LOAs such as B046, B036 and D195, the MEL, and the timing that keeps a new jet flying overseas.

Short answer: almost nothing operational transfers with the airplane. The FAA issues Part 91 Letters of Authorization "to the person exercising operational control and not to a specific aircraft," and "LOAs are nontransferable" (FAA Order 8900.1, Volume 3, Chapter 2, Section 2). The seller's registration ends at transfer of ownership (14 CFR 47.41(a)). So the buyer registers the aircraft and applies, in its own name, for every LOA it needs: A001, the MEL LOA (D195 or D095), B046 for RVSM where a specific authorization is needed, and the oceanic set (A056, B036, B039). What does carry over is the aircraft's own eligibility: its RVSM compliance, its equipment and, for the streamlined process, its manufacturer's capability statement.

What ends at closing

Registration. Under 14 CFR 47.41(a), a Certificate of Aircraft Registration is effective unless registration has ended because, among other things, "the ownership is transferred." The buyer applies under 47.31 with the registration application, the bill of sale (or other evidence of ownership) and the fee. Section 47.31(c) lets the applicant carry the second copy of the application as temporary authority, but 47.31(c)(1) limits that authority to "operation within the United States," and 14 CFR 91.203(a)(2) accepts that copy only "for operation within the United States." A first trip abroad has to wait for the registration certificate.

Part 91 LOAs. 8900.1, Volume 3, Chapter 2, Section 2, paragraph 3-2-2-5I, says an LOA is issued to the operator, so multiple operators can each hold LOAs for one aircraft. Paragraph 3-2-2-11 lists the changes that allow administrative reissuance without reapplying: operator name change, change of principal base of operations or mailing address, change of Responsible Person, removing an aircraft, or change of aircraft registration number. A new owner is not on that list, and the note that follows says "LOAs are nontransferable" and that inspectors "must ensure an operator name change is not a transfer of the LOA to another operator." When the seller stops operating the aircraft, its LOA becomes invalid for that aircraft.

The MEL authorization. AC 91-67A, paragraph 3.3.3, says LOAs are issued to the operator with operational control and that a lessee "cannot use an MEL authorization issued to any other person." The same logic applies to a buyer. You request your own D195 or D095.

What carries over

RVSM eligibility. AC 91-85B, paragraph 4.3.5.1, says the FAA tracks height-monitoring by serial number and that "transfer of ownership or the registration number of a properly maintained aircraft does not affect aircraft RVSM status" under Part 91 Appendix G, Section 9. If you need a B046 LOA (for example for foreign airspace that requires a specific approval), the AC's decision matrix treats "a new proposed RVSM operator ... using an existing RVSM-compliant aircraft" as Authorization Group II, a new authorization based on an existing approved element (AC 91-85B, paragraph 5.3.2 and Appendix F). You still apply, but you rely on the aircraft's existing compliance rather than proving it again. See RVSM authorization for Part 91 operators.

Equipment and capability. The aircraft's RNP, data link and RVSM capability stay with the airframe, and so does the manufacturer's documentation. For the streamlined application, the manufacturer's Aircraft Statement of Capability is the aircraft evidence, though 8900.1, Volume 3, Chapter 18, Section 15, says it expires 90 days after the manufacturer signs it, so request a current one.

Training. Your crews' training records stay with them. The streamlined guidance accepts training from a course on a current Training Statement of Compliance, for at least one complete crew.

Timing the applications

The streamlined guidance is the most useful here. 8900.1, Volume 3, Chapter 18, Section 15, paragraph 3-18-15-7, says inspectors "should attempt to issue LOAs as close as possible to the date the operator takes operational control of the aircraft," and paragraph 3-18-15-11 says they should begin processing and preparing draft LOAs in anticipation of that date. Applying before closing, with the expected date in the application, gives the office the chance to have LOAs ready when you take operational control. It does not promise that they will be.

For an existing operator adding an aircraft, several streamlined LOAs drop some verification items when you are adding an aircraft to an issued and active LOA (Table 3-18-15B).

Who the operator is

8900.1, Volume 3, Chapter 2, Section 2, says the applicant must give the correct legal name of the operator, which "will be listed on all 14 CFR part 91 LOAs," and must apply to the Flight Standards office whose service area covers its principal base of operations, meaning the physical place where operational control decisions are made. If the buyer is a newly formed LLC, that LLC is the operator, and a management company "may not exercise operational control." If the purchase uses a trust or a leasing structure, decide who the operator is before applying; AC 91-85B, paragraph 5.6.1.2, notes that the legal operator "will generally not be an owner trustee not operating the aircraft for its own business." If the operator will dry lease the aircraft from the owning entity, see the 91.23 truth-in-leasing clause.

Checklist for the buyer

• Identify the operator entity and its principal base of operations.
• File the registration application, bill of sale and fee; plan no international flights on the temporary copy.
• Obtain the AFM supplements, RVSM compliance records and current ASOC for the airframe.
• Collect crew training records for oceanic, NAT HLA, RVSM and data link as needed.
• Prepare a D195 MEL against the current MMEL revision for your configuration, or a D095 procedures document.
• Apply for A001 and the operational LOAs you need, with the expected closing date.
• If RVSM requires a specific approval for your routes, apply for B046 as a Group II request.
• Update the international operations manual for your operator name and fleet.
• Ask the seller to request removal of the aircraft from its LOAs once it stops operating it.

What you submit and who submits it

The buyer, as the operator with operational control, submits the registration application to the FAA Registry and the LOA application to its responsible Flight Standards office. A third party can submit the LOA application on behalf of an operator that retains operational control.

We prepare the A001 information, the streamlined or individual LOA requests, the D195 MEL and the B046 request, with step-by-step submission instructions timed to your closing. You sign and submit. The FAA decides what it issues and when.

Frequently asked questions

Can the seller's LOAs be transferred to us at closing?

No. 8900.1 says LOAs are nontransferable and are issued to the operator, not the aircraft.

Does the aircraft need a new RVSM height-monitoring flight after a sale?

Not because of the sale. AC 91-85B says transfer of ownership or registration of a properly maintained aircraft does not affect its Section 9 RVSM status.

Can we fly to Canada on the temporary registration copy?

No. 14 CFR 47.31(c) and 91.203(a)(2) limit the temporary copy to operation within the United States.

Have it prepared

A001 issuance is $350, the streamlined application package $1,725, the D195 MEL from $550 and the B046 package $775. The Part 91 Turbine Starter combines the streamlined application, MEL and B046 for from $2,550. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• FAA Order 8900.1, Volume 3, Chapter 2, Section 2, Responsibility for Part 91 LOAs (CHG 976)
• FAA Order 8900.1, Volume 3, Chapter 18, Section 15, Streamlined Part 91 Operational Approvals (CHG 973)
• AC 91-85B (editorial update), Authorization of Aircraft and Operators for Flight in RVSM Airspace
• AC 91-67A, Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91
• 14 CFR 47.41, Duration and return of Certificate
• 14 CFR 47.31, Application
• 14 CFR 91.203, Civil aircraft: Certifications required
• 14 CFR 91.23, Truth-in-leasing clause requirement in leases and conditional sales contracts

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.