Tail Number Changes, Tail Number Changes, Tail Number Changes! Oh My!
By: Stewart Lapayowker
It is not uncommon for an aircraft buyer to want to change the registration number on an aircraft, and it is similarly common for a seller to want to “retain” the registration number of the aircraft that he or she is selling if it has personal meaning or for other reasons. Unfortunately, changing the registration number of an aircraft is not like obtaining a “vanity”plate for your car. There is a process, and it takes some time, and there are some definite traps of which to be wary.
One trap to be wary of is that if there is a pending request for a number change, the FAA will not process a transfer (or bill of sale) for the aircraft. So, the request needs to be withdrawn. This is why we suggest that requests for number changes in connection with a purchase/sale only be made at closing. So, don’t be anxious to make that request until you’ve spoken with an aviation professional, or you will be sorely disappointed at closing.
Let’s take an example. In this example, Buyer owns an aircraft and is buying a second aircraft (we’ll call it New Aircraft even though it is pre-owned). Eventually, the old aircraft will be sold. Buyer likes the number on Old Aircraft (N12OA) and wants to put it on New Aircraft (N56NA). Here’s the process:
1. Reserve a number for assignment to Old Aircraft. We’ll use N12OB. Usually, you like it to be a number that will not require too much painting over the old number. Here, only 1 letter would need to be painted over. It takes about 1 to 2 weeks for the reservation to appear in the system.
2. Request that the FAA assign Special Registration Number N12OB to Old Aircraft to replace N12OA.
3. As number changes are not a priority item for FAA, approximately 4 to 6 weeks after the request, the FAA will issue FAA Form 8050-64 authorizing that the number on Old Aircraft can be changed to N12OB. This authorization is valid for a year.
4. Once the new number has been ‘placed’ on Old Aircraft (usually a sticker or painted), Form 8050-64 should be signed and the original filed with FAA. The copy of the signed and dated form is stapled to the existing registration card and then you can legally operate under the new number N12OB. There are some other things to do as well, like re-strap the transponders and obtain a replacement CofA with the new number, and change numbers on documentation, but that’s beyond the scope of this explanation.
5. When the 8050-64 form is filed with FAA, you’ll want to be sure that the aviation professional that files the form reserves the old number N12OA back to the owner of Old Aircraft (which we are assuming here will be the owner of New Aircraft). The reservation of the old number back to the owner of Old Aircraft will be reflected in the FAA system in about 2 weeks. Yes, 2 weeks.
6. When the FAA system shows that N12OA has been reserved back to the owner, it’s time to make the second request. Either at the closing on the acquisition of New Aircraft or thereafter (it depends upon whether the reservation of N12OA has been completed before or after acquisition of New Aircraft), have your aviation professional submit a request to FAA to change the number on New Aircraft from N56NA to N12OA.
7. Approximately 4 to 6 weeks after the request, the FAA will issue FAA Form 8050-64 authorizing that the number on New Aircraft can be changed from N56NA to N12OA. This authorization is valid for a year.
8. Once the new number has been ‘placed’ on New Aircraft (usually a sticker or painted), Form 8050-64 should be signed and the original filed with FAA. The copy of the signed and dated form is stapled to the existing registration card and then you can legally operate under the new number N12OA. Of course, if you want to keep N56NA, you’ll need to request that the FAA reserve it back to owner.
How many weeks did you count before the final number was able to be placed on New Aircraft? If we were ambitious, 1 week to reserve a number for Old Aircraft, 4 weeks for the 8050-64 form authorizing change from N12OA to N12 OB to be issued, 1 week for N12OA to be reserved back to owner, 4 weeks for the 8050-64 form authorizing change from N56NA to N12OA. Total: 10 weeks.
So when you hear “let’s change the number,” it’s a little more complicated than that.