See attached “Trust Issue” letter from FAA’s Chief Counsel.

From Jim Bennett, PNBAA President, and David D. Warner, PNBAA’s General Counsel: Earlier this month, FAA announced a retroactively effective “moratorium” on the processing of aircraft registrations for owner-trusts, where the owner-beneficiary is a non-US-citizen. A very large number of US-based operating companies, lenders and leasing companies have utilized this owner trust structure to hold title and registration for decades – statutes and rules have clearly permitted its use. Making the change retroactive could have also put existing owner-trust registrations in jeopardy. A coalition, which included the PNBAA, diligently worked to present concerns and propose alternatives to the FAA. Although the industry may continue to apply this useful registration technique, the FAA will continue to review this topic and likely will initiate an orderly review and (possibly) rule making process at some point in the future. We would like to thank the many members of a coalition of trade groups (including PNBAA), Oklahoma City title lawyers and other interested parties that came together so quickly and worked so hard to represent our aviation industry so effectively on this matter. In particular, we thank Andrea Brantner (GE Capital Aviation Services) for her outstanding leadership in spearheading the coalition’s efforts!