Notice of Policy Clarification for the Registration of Aircraft to U.S. Citizen Trustees in Situations Involving Non-U.S. Citizen Trustors and Beneficiaries

Sep 16, 2026

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Federal Aviation Administration (FAA) issues a policy clarification regarding the registration of aircraft when ownership is held in trust by U.S. citizen trustees while trustors and beneficiaries are non-U.S. citizens. The notice explains how FAA oversight and access to operational and maintenance information influenced the review, and how the clarification supports compliance with 14 CFR 47.7. It summarizes prior public engagement, written submissions, and proposed policy updates to align trust arrangements with FAA rules and practices.

LanguageEnglish

CategoryLetters

FormatPDF

Pages49

Reading Time17 min

AccessFree to download

Background

Non-citizen trusts and FAA review

Public meeting and written comments

Notice and proposed policy clarification

February 9, 2012 proposed clarification

Second meeting and comment extensions

Effective date and contact information

This document is scheduled to be published in the Federal Register on 06/18/2013 and available online at [http://federalregister.gov/a/2013-14434](http://federalregister.gov/a/2013-14434), and on [FDsys.gov](FDsys.gov) [4910-13] DEPARTMENT OF TRANSPORTATION Federal Aviation Administration 14 CFR Chapter I Docket No. FAA-2011-0012 Notice of Policy Clarification for the Registration of Aircraft to U.S. Citizen Trustees in Situations Involving Non-U.S. Citizen Trustors and Beneficiaries AGENCY: Federal Aviation Administration (FAA), DOT. ACTION: Notice ofFAA policy clarification. SUMMARY: Notice is hereby given of the FAA’s clarification of its policy regarding the registration of aircraft to U.S. Citizen Trustees in situations involving non-U.S. citizen trustors and beneficiaries. DATES: Effective Date: The policy described herein is effective [INSERT DATE 90 DAYS FROM DATE OF PUBLICATION IN FEDERAL REGISTER] . FOR FURTHER INFORMATION CONTACT: Joseph Standell at 405-954-3296, Office of Aeronautical Center Counsel, Federal Aviation Administration, 6500 S. MacArthur Blvd., Oklahoma City, Oklahoma 73169. SUPPLEMENTARY INFORMATION: Background The FAA has been reviewing policies and practices regarding the registration of aircraft in the United States involving U.S. citizen trustees and non-U.S. citizen trustorsand beneficiaries. Such arrangements are commonly referred to as non-citizen trusts. The FAA began its review in part because of problems the FAA has experienced in obtaining important operational and maintenance information concerning such aircraft from the registered owners, i.e., the owner trustees. The problems in obtaining such information in turn affected the FAA’s ability to conduct fully effective oversight of such aircraft when operated outside the United States, and to provide foreign civil aviation authorities with information on those operations in support of the safety oversight activities of those authorities. The FAA also undertook the review of non-citizen trusts to assure compliance with the FAA regulatory requirements for non-citizen trusts contained in 14 CFR 47.7. As part ofits review of non-citizen trusts, the FAA published a notice of public meeting inviting members of the public to discuss the use of non-citizen trusts to register aircraft in the United States (76 FR 23353, April 26, 2011) . In the notice, the FAA set forth several questions in order to elicit a robust discussion of the issues. Among other things, the FAA summarized the requirements in existing U.S. law that only an “owner”may register an aircraft, and that generally speaking only citizens of the United States that are owners are eligible to register aircraft. Thus, the FAA Aircraft Registry is an“owner” registry; it is not an “operator” registry. The FAA met with interested members of the public on June 1, 2011, in Oklahoma City, Oklahoma. Representatives of trade associations, law firms, aircraft manufacturers, lenders, lessors, aircraft operators, trustees and others were present. The proceedings of that meeting were transcribed, and the transcript was made available for purchase from the court reporter to members of the public. The FAA received a number of written comments from members of the public in response to the questions raised in the April 26, 2011, Federal Register notice. The FAA also received written comments in response to its request at the conclusion of the public meeting for additional input from the meeting participants and all others who had an interest in the issues surrounding non-citizen trusts. An organization (the Aviation Working Group, or AWG) that represents a wide range of aviation industry participants on aviation regulatory and commercial issues submitted a document on May 26, 2011, in which its members and other supporting entities shared their views concerning the various questions posed by the FAA in its April 26, 2011 Federal Register notice. The AWG also participat

FAQs

What policy does the FAA clarify in this notice?

The FAA clarifies its policy on registering aircraft in situations where U.S. citizen trustees hold aircraft under arrangements involving non-U.S. citizen trustors and beneficiaries.

Why did the FAA begin reviewing non-citizen trusts?

The FAA started the review due to difficulties obtaining operational and maintenance information from registered owners (owner trustees), which affected oversight and the ability to support safety oversight by foreign civil aviation authorities. The review also aimed to assure compliance with 14 CFR 47.7.

How did the FAA gather input from the public?

The FAA held a public meeting on June 1, 2011, and later received written comments following the April 26, 2011 Federal Register notice. After a February 9, 2012 Notice of Proposed Policy Clarification, the FAA held a second public meeting on June 6, 2012 and extended the comment deadline to July 6, 2012.

Sep 16, 2026

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