Chapter 8 - Registration of an Aircraft

8.1  LEGAL CUSTODY AND CONTROL - GENERAL

CARs 202.13(2), 202.35

Unless authorized otherwise, the Canadian Aviation Regulations require that aircraft operating in Canada be registered. In Canada, a Certificate of Registration is issued to the individual or entity that has legal custody and control of an aircraft (for the operation of a leased aircraft by a non-registered owner refer to CARs 203 and the Aircraft Leasing Operations Administrative Procedures Manual). When a change of legal custody and control requires the issuance of a new Certificate of Registration, the current Certificate of Registration is cancelled and the registered owner must notify Transport Canada in writing within 7 days of the transfer of legal custody and control.

For the new owner to continue operation of the aircraft, they must apply to register the aircraft in their name. They may either activate the Interim Certificate of Registration (if they have a newer certificate from the previous owner which has the Interim on it) or await issuance of a Continuing Certificate of Registration in their name before they can fly the aircraft. If they have an older form which does not have an Interim to activate and they want to fly the aircraft immediately, they should apply for a Temporary Certificate of Registration.

A Certificate of Registration is NOT a certificate of title. In Canada, aircraft are registered based on who has legal custody and control, and not on who has financial title to the aircraft. There is no title registry for aircraft in Canada. Thus, a foreign entity may be the financial owner of an aircraft, but not be eligible to be the registered owner of a Canadian aircraft. The foreign entity could enter into a lease agreement with a Canadian entity and, through that lease agreement, the Canadian entity becomes eligible to be the registered owner of the aircraft. Persons wanting to know if there are liens against an aircraft must contact the various provincial government offices responsible for maintaining personal property registries (see Appendix D).

There may be situations arising where you will become aware of a challenge to the legal custody and control of an aircraft. For example, co-owners or a lessor and lessee may be embroiled in a dispute as a result of business arrangements or personal circumstances. People may attempt to have you change the name in which an aircraft is registered if a dispute has arisen.

In such cases, Aircraft Registration staff should NOT try to determine which of the disputing parties has legal custody and control of the aircraft. You should be careful not to become embroiled in such disputes. Rather, our regulations should be applied at all times. It is advised that you not take any action until the parties involved have solved the dispute themselves or through a court of law or other authority.

Legal advice from headquarters has been given, thatin all instances, court orders should be followed. Thus, if a court order is submitted to you as proof of a change in legal custody and control of an aircraft, action in accordance with that court order should be taken.

8.2  LEGAL CUSTODY AND CONTROL - REQUIRED DOCUMENTATION

Standards 222.16

Before a Certificate of Registration can be issued, the applicant must provide proof that they have legal custody and control of the aircraft. Various documents can be used to meet this requirement. In all cases the name on the legal document must match the applicant’s. All documentation should identify the aircraft and all parties involved in the legal custody and control ownership transfer. A photocopy or facsimile of the document is acceptable. If any doubt exists as to the validity of the document the original may be requested.

Imported aircraft must show custody and control transferring from a foreign entity to the Canadian entity. New Canadian manufactured aircraft will show the transfer from the Canadian manufacturer to the applicant. For new amateur-built aircraft, the owner generally submits a written declaration that they are the sole and titled owner of the aircraft. Ultra-light aeroplanes built from plans require the owner to submit a statement to this effect. Ultra-light kits would require a bill of sale from the kit manufacturer.

When an aircraft that is already registered in Canada transfers custody and control, the legal document must be signed by the last registered owner unless it had been registered pursuant to a lease agreement. When the owner who is transferring the aircraft, is not the registered owner or the lessor, the consecutive bills of sale or legal document from the last registered owner or lessor, to the applicant must be submitted.

Bill of Sale

A bill of sale must identify the aircraft, the seller and the purchaser. It should state that all right and title have been transferred and be dated. In the case of an aircraft that has co-owners, (either sellers or purchasers) all owners should be identified. All co-owners must sign the bill of sale when selling the aircraft.

Lease Agreement

When an aircraft is leased, the lessee applies to be the registered owner (for lease agreements between commercial operators where the lessor is to remain the registered owner of the aircraft, refer to CARs 203 and the Leasing Procedures Manual).

Providing there is no restriction otherwise, an aircraft may be subject to a sub-lease(s). The lessee identified in the sub-lease would to apply to be the registered owner. Any sub-lease commencement and termination dates must fall within the same time period as the "head" lease.

To establish an applicant for registration as an aircraft owner, as per paragraph 222.16(1)(b), a lease or other agreement shall contain the following information and statements, as set out in the CARs standard 222.16(2):

  1. the commencement and expiry dates of the lease or agreement;

  2. the names of the parties to the lease or agreement;

  3. a description of the aircraft, including the aircraft marks, name of the manufacturer, model designation and serial number;

  4. a statement that the aircraft shall be in the legal custody and control of the lessee or of the transferee, for the duration of the lease or agreement;

  5. a statement that responsibility for the airworthiness and maintenance of the aircraft is vested in the lessee, or in the transferee, for the duration of the lease or agreement;

  6. a statement that the lessor or transferor will not provide directly or indirectly any flight crew to operate the aircraft for the duration of the lease or agreement;

  7. a statement specifying whether or not sub-leasing, or assignment of the agreement, is permitted under the lease or agreement;

  8. a statement describing the requirements and procedures for early termination of the lease or agreement; and

  9. a statement that no other part of the lease or agreement and that no other legal document between the parties to the lease or agreement exist, concerning the aircraft described in the lease or agreement, which would contradict any statement that is required to be included in the lease or agreement under this subsection.

If the lease or agreement does not contain this information and these statements, then the applicant should be contacted, with a view to having the lease amended to reflect the standard. If there is any disagreement on the applicant's part, they are to indicate where each of the provisions in the standard are met in the lease or agreement. They may do so either by annotating the lease or agreement in the margin OR by completing the form 26-0309 entitled "Annex to Application for Registration of a Leased Aircraft".

If you are still not satisfied that the requirements of the standard have been met, then the lease is to be forwarded to HQ where a legal opinion will be sought. The applicant should be made aware that this could take some time. The aircraft is NOT to be registered unitl the matter has been resolved.

(amended 2000/06/06)

Lease Extension

A lessee and lessor may agree to extend a lease beyond the termination date. An extension may be a complete new lease agreement that contains all the required clauses. It may also be a statement that they have agreed to extend the lease agreement and give the new termination date. Extensions must be signed by both the lessee and lessor. The extension start date must be prior to or immediately upon the termination of the previous lease on record with Transport Canada. Copies of lease extensions must be received by Transport Canada prior to 7 days after the termination date otherwise the Certificate of Registration is cancelled. CARs 202.57(1)(c) refers.

Repossession

Where an application for registration is made by a person who has repossessed an aircraft pursuant to a chattel mortgage or a conditional sale, the applicant must submit a copy of that same document or other documentation that supports their right to seize. The document must include the right to repossess the aircraft. An affidavit stating that all conditions of the agreement regarding repossession have been complied with is also required. Alternatively, the former owner can sign a statement releasing their interest in the aircraft. Provincial laws may differ regarding repossessing assets.

Bankruptcy

A registered owner who has declared bankruptcy may have a receiver appointed to handle their assets. Transfer documents should be submitted with a copy of the legal document that appointed the receiver to act on behalf of the owner. In some cases, it is a Debenture that has been agreed to and signed by the registered owner or a Court Order.

Estate

A person who inherits an aircraft would need to provide a copy of the will or other legal document that showed they inherited the aircraft.

A bill of sale from an estate must be signed by the executor or administrator and must be accompanied by a copy of their appointment.

Affidavit

If, after a serious attempt to obtain correct documentation, the applicant cannot supply all of the consecutive legal transfer documents, then a notarized affidavit may be supplied. The affidavit must identify the aircraft, state the circumstances of the transfer, why the document is not available and that they have sole title to the aircraft. For multiple transactions, it is preferable that the affidavit be from the seller who was unable to supply the document that transferred the aircraft to them. If the seller can not be located then the affidavit can be from the applicant.

Trust

An aircraft is not to be registered in the name of a trust but of the "trustee" as set out in the trust deed. A copy of the deed would be required. Seek legal advice through Headquarters to determine if the "trustee" qualifies to be the registered owner pursuant to the trust. A trust may not always be empowered to transfer legal custody and control of an aircraft.

8.3  LEGAL CUSTODY AND CONTROL - CHANGE IN DOCUMENTATION

CARs 202.57(2)

When the document by which the registered owner of an aircraft has legal custody and control ceases to be in effect, the Certificate of Registration is cancelled unless the registered owner retains legal custody and control after the document ceases to be in effect and submits to Transport Canada, within 60 days, a copy of the new document by which legal custody and control is retained. There is no need for the owner to apply for a new Certificate of Registration as long as legal custody and control of the aircraft remains with that current registered owner.

Some situations where this may apply are:

  1. the current Certificate of Registration was issued pursuant to a lease agreement and is subsequently sold by the lessor to the registered owner;

  2. the current Certificate of Registration was issued pursuant to a lease agreement and is subsequently sold by the lessor to a new owner who in turn leases the aircraft back to the registered owner;

  3. the current Certificate of Registration was issued pursuant to a bill of sale in the name of the registered owner who subsequently sells the aircraft and leases it back.

As the registered owner remains the same no application for the issuance of a new Certificate of Registration is required. CCARCS needs to be updated to reflect the change of documentation. Copies are forwarded to Headquarters for their files.

8.4  TYPES OF REGISTRATION

CARs 202.17(1)

Currently, aircraft are registered as commercial, private or state. This is indicated on the "purpose" box on the Certificate of Registration.

A commercial purpose Certificate of Registration can be issued to either an individual or a corporation (CARs 202.17(4)). The owner should intend to operate the aircraft under the authority of an Air Operator Certificate (AOC) that is issued by Commercial and Business Aviation or General Aviation - Flight Training. The Certificate of Registration can be issued prior to the issuance of an AOC but should be issued with a covering letter that stipulates it does not give the operator authority to operate commercially unless they have an AOC. It should be noted that ultra-light aeroplanes that are registered to the holder of a Flight Training Unit Operator Certificate would still be registered for private purposes.

A private purpose Certificate of Registration can be issued to either an individual or a corporation. All ultra-light or advanced ultra-light aeroplanes must be registered as private purpose. A balloon is also only issued private purpose Certificate of Registration, even if operating with a Special Flight Operating Certificate issued pursuant to the CARs Part VI.

A state purpose Certificate of Registration can only be issued to a civil aircraft if it is both owned by and exclusively used in the service of a government in Canada (CARs 202.17(3)). A legal opinion has been given that a "government" can include any level such as federal, provincial or municipal.

8.5  TYPES OF CERTIFICATES OF REGISTRATION

CARs 202.17(2), and CAR 202.25

Aircraft can be operated in Canada under four types of Certificates of Registration. They are:

  1. a Provisional Certificate of Registration;
  2. a Temporary Certificate of Registration;
  3. an Interim Certificate of Registration; and
  4. a Continuing Certificate of Registration.

Owners and aircraft must meet Canadian eligibility requirements before a Certificate of Registration can be issued. A Certificate of Registration must be on board the aircraft during flight.

8.6  PROVISIONAL CERTIFICATE OF REGISTRATION

A Provisional Certificate of Registration is issued to an aircraft that is being imported into Canada, or is not yet registered in Canada, but is to be operated for the purpose of transporting it from one location in Canada to another location in Canada. Aircraft issued with a Provisional Certificate of Registration are considered to be "nationally" registered in Canada, however, aircraft and owner details are not actually recorded on the Canadian Civil Aircraft Register.

A provisional Certificate of Registration is valid only in Canadian airspace and is cancelled or expired upon completion of the flights, or upon the specified expiry date, whichever occurs first. Approval must be obtained from the foreign aviation authority for flight in foreign airspace (see Chapter 7.2 for information on issuing a Provisional Certificate of Registration).

NOTE:  At the Canadian Aviation Regulation Advisory Council (CARAC) Part II Technical Committee meeting in November 1998, it was agreed that a Provisional Certificate of Registration may also be issued to an aircraft which flies into Canada from a country, and then proceeds on to a third country for maintenance, prior to it returning to Canada where application will be made for a Continuing Certificate of Registration. For example, an aircraft which has been removed from the British register flies to Canada on a Provisional Certificate of Registration and then proceeds on to the U.S. for maintenance. Once maintenance is complete, the aircraft returns to Canada and application for a Continuing Certificate of Registration is made. Although not common, this situation can occur and should be facilitated through the issuance of a Provisional Certificate of Registration.

8.7  CONTINUING CERTIFICATE OF REGISTRATION - INITIAL REGISTRATION

CARs 202.16 and Standards 222.16

When a Continuing Certificate of Registration is issued to a newly-manufactured or imported aircraft, the aircraft and owner information are then entered onto the Canadian Civil Aircraft Register. A Continuing Certificate of Registration does not have an expiry date. It remains valid until there is a change of custody and control of the aircraft (see Chapter 5 for information on who is eligible to be a registered owner and Chapter 8.8 for information on change of custody and control).

These steps should be followed to add an aircraft onto the Canadian Civil Aircraft Register:

  1. A photo or etching of the aircraft’s identification plate is required to confirm the manufacturer’s name and model designation.

  2. Notice of de-registration from a foreign air authority, unless it is a new Canadian manufactured aircraft, a new Canadian amateur-built aircraft or an ultra-light aeroplane that was assembled in Canada.

  3. If it is an amateur built aircraft, confirm that the aircraft is ready for or has had the final airworthiness inspection. The Recreational Aircraft Association (RAA), Airworthiness Inspection Representative - Amateur Built Aircraft (AIR-ABA) or Transport Canada Maintenance and Manufacturing Branch would have this information.

  4. If the aircraft does not have a Type Approval or Type Certificate, then confirm with Maintenance and Manufacturing that they will be issuing a Flight Authority for the aircraft (ultra-lights excluded).

  5. If it is an Advanced Ultra-light aeroplane, then a Statement of Conformity (SOC) is also required (see Ultra-light Transition Strategy accessible from the Aircraft Registration & Leasing Web Site for a copy of the SOC).

  6. An application form for registration (form 26-0521 for Ultra-light or Advanced Ultra-light Aeroplanes; form 26-0522 for all other aircraft).

  7. If the applicant is an entity, a copy of the provincial or federal government document by which the entity is formed, copy of the entity’s Articles of Incorporation which clearly stipulate signing authority and their Certificate of Incorporation, along with a copy of the entity’s current Annual Return and Articles of Incorporation which must be submitted.

  8. Proof of legal custody and control ownership in the same name as the application form. For imported aircraft, the bill of sale or lease agreement would originate from the foreign owner. In the case of a Canadian amateur-built aircraft, a letter stating the applicant is the sole and titled owner. For newly manufactured aircraft, the bill of sale or lease agreement would originate from the manufacturer.

  9. A fee of $110 applies.

  10. If all documentation is in order, update and print a Certificate of Registration through CCARCS. The Owner Registration Date and Certificate Issue Date will be the date the information is entered into CCARCS.

  11. If there is a discrepancy in the documentation, the applicant must be advised of the additional requirements. This may be done by phone or by letter. The Continuing Certificate of Registration should not be issued until all requirements have been met. (see Chapter 8.9 for information on issuing a Temporary Certificate of Registration).

  12. All copies of the Continuing Certificate of Registration must be signed by a General Aviation Inspector or Licensing Officer.

  13. A copy of the application and the supporting documentation along with a copy of the Certificate of Registration is sent to Headquarters.

  14. A Notification of Change of Owner(s) card (form 26-0519) is to be is attached to the Certificate of Registration and then mailed to the owner.

Eligibility for a flight authority

IMPORTANT NOTE:

Standard 222.16(e) is clear that one of the requirements to be met PRIOR TO REGISTRATION is that the aircraft be eligible for a flight authority pursuant to Part V of the CARs. Maintenance and Manufacturing should make this determination PRIOR TO REGISTRATION. It is not a correct interpretation of the standard to assume that, if registered, the aircraft will become eligible for a flight authority. Eligibility must precede registration.

In the case of an aircraft which does not have a Canadian Type Certificate, the Maintenance and Manufacturing Branch in the region will determine if the aircraft is eligible for a flight authority. If the intended flight authority is a Certificate of Airworthiness, the Maintenance and Manufacturing Branch in the region may choose also to discuss the matter with the Aircraft Certification Branch in Headquarters. In any event, registration does not confer eligibility - the aircraft must be determined to be eligible for a flight authority PRIOR TO REGISTRATION and you should be satisfied that Maintenance and Manufacturing has given this approval prior to proceeding with the registration process.

8.8  INTERIM CERTIFICATE OF REGISTRATION - RE-REGISTRATION (CHANGE OF OWNERS)

CARs 202.36 and Standards 222.36

If the aircraft is already registered in Canada and there is a change of legal custody and control, a new Continuing Certificate of Registration must be issued (for lease agreements involving commercial operators where the registration remains in the name of lessor, refer to CARs 203 and the Leasing Procedures Manual).

While the new owner applies to register the aircraft in their name, they operate the aircraft on an Interim Certificate of Registration. The Interim Certificate of Registration is attached to the Continuing Certificate of Registration and is activated at the time of change of legal custody and control of the aircraft.

An Interim Certificate of Registration is valid for 3 months from the date of the change of legal custody and control (e.g. legal custody and control changes on April 4. The Interim Certificate of Registration would be valid until midnight on July 3). An Interim Certificate of Registration can be used in the commercial purpose, if the owner meets AOC requirements, even if the previous Certificate of Registration was issued in the private purpose.

An Interim Certificate of Registration is not transferable. If the new owner activates the Interim Certificate of Registration and then sells the aircraft before being issued a new Continuing Certificate of Registration, the Interim Certificate of Registration is invalid at the time of the second sale.

The following steps should be followed to issue a Continuing Certificate of Registration to the new owners:

  1. The new owner returns the existing, original copy of the Certificate of Registration with the completed application form. The application form is found on the existing Continuing Certificate of Registration.

  2. If the applicant is an entity, a copy of the provincial or federal government document by which the entity is formed, along with their articles of incorporation which clearly stipulate signing authority for the entity and a copy of the annual return must be submitted.

  3. If the Certificate of Registration has been lost, a written declaration of this must be submitted along with application form 26-0521 (ultra-lights) or 26-0522 (all other aircraft).

  4. If the aircraft has changed owners after the application form on the Certificate of Registration was completed, then application form 26-0521 or 26-0522 is completed by the subsequent new owners. The Certificate of Registration must still be submitted.

  5. Proof of legal custody and control ownership in the name of the applicant is required. This should be from the last owner identified with Transport Canada with continuity to the new applicant.

  6. A fee of $110 applies.

  7. In the case of an advanced ultra-light aeroplane a Fit for Flight Form (FFFF) signed by both seller and purchaser is also required (see the Ultra-light Transition Strategy for a copy of the FFFF accessible from the Aircraft Registration Leasing Web Site).

  8. If all documentation is in order, update and print a Continuing Certificate of Registration through CCARCS. The Owner Registration Date and Certificate Issue Date will be the date the information is entered into CCARCS unless a valid Temporary Certificate of Registration, to the same owner, is on record. In that case, the Owner Registration Date remains the date that the Temporary Certificate of Registration was issued and the Certificate Issue Date will be the date that the Continuing Certificate of Registration is printed in CCARCS.

  9. If there is a discrepancy in the documentation, the applicant must be advised of the additional requirements. This may be done by telephone or by letter. The Continuing Certificate of Registration should not be issued until all requirements have been met. See Chapter 8.9 for information on issuing a Temporary Certificate of Registration.

  10. All copies of the Certificate of Registration must be signed by a General Aviation Inspector or Licensing Officer.

  11. A copy of the application and the supporting documentation along with a copy of the Certificate of Registration is sent to Headquarters.

  12. A Notification of Change of Owner(s) card (form 26-0519) is to be attached to the Certificate of Registration and mailed to the owner.

8.9  TEMPORARY CERTIFICATE OF REGISTRATION

CARs 202.25(1)(b)

A Temporary Certificate of Registration is issued for various reasons:

  1. on request when the Interim Certificate of Registration is about to expire and the Continuing Certificate of Registration has not been issued because of inadequate documentation;

  2. on request when the Continuing Certificate of Registration is ready for mailing, but the owner wishes to operate the aircraft immediately and the Interim Certificate of Registration is not available; and

  3. on request when the owner has lost the Certificate of Registration and wishes to operate the aircraft immediately. A Temporary Certificate of Registration does not have any provision to transfer legal custody and control of the aircraft. Should legal custody and control change while a Temporary Certificate of Registration is in force, it becomes invalid. A Temporary Certificate of Registration can be sent by facsimile.

These steps should be followed to issue a Temporary Certificate of Registration to a new owner:

  1. An application form for registration is required.

  2. Advise the owner about the other documentation required and of any errors in the submitted documents (see Chapter 8.7 or 8.8).

  3. A fee of $65 applies. This is in addition to the $110 that would apply for a Continuing Certificate of Registration.

  4. Update and print a Temporary Certificate of Registration through CCARCS. The Owner Registration Date and Certificate Issue Date will be the date the information is entered into CCARCS.

  5. The Temporary Expiry Date is 3 months from the Certificate Issue Date.

  6. A Temporary Certificate of Registration must be signed by a General Aviation Inspector or Licensing Officer.

  7. A copy of the Temporary Certificate of Registration is sent to Headquarters.

  8. The file should be brought forward to ensure that the applicant submits the required documentation to be issued a Continuing Certificate of Registration.

These steps should be followed to issue a Temporary Certificate of Registration when the owner has lost their Certificate of Registration C of R:

  1. Notification of the loss can be by phone or letter. If by phone, it must be followed up with a written declaration in the form of a letter or by using a Declaration of Loss form supplied by Transport Canada.

  2. Print a Temporary Certificate of Registration through CCARCS. The Owner Registration Date does not change. The Certificate Issue Date will be the date the information is entered into CCARCS.

  3. The expiry date of the Temporary Certificate of Registration is 3 months from the Certificate Issue Date.

  4. A fee of $65 is required for the Temporary Certificate of Registration. This is in addition to the $35 that would apply to re-issue the Continuing Certificate of Registration.

  5. A Temporary Certificate of Registration must be signed by a General Aviation Inspector or Licensing Officer.

  6. A copy of the Temporary Certificate of Registration is sent to Headquarters.

  7. The file should be brought forward to ensure that the applicant submits the fee and declaration of loss so a Continuing Certificate of Registration can be issued.

8.10  RE-REGISTRATION - CORPORATE AMALGAMATION

CARs 202.57(1)(b)

Whenever a corporate entity that is the registered owner of an aircraft amalgamates with another corporate entity, the Certificate of Registration is cancelled. The new entity must apply to be the registered owner (see Chapter 8.8). The fact that both entities may be controlled by the same individual or retain one of the original entity names does not change the legal requirement to reapply for registration. (Note: The paperwork submitted should indicate a new corporation identity number which will have been given by the province/federal government to the newly amalgamated corporate entity.)

If two unincorporated businesses owned by the same individual subsequently incorporate and transfer the aircraft to the entity, the aircraft would require re-registration.

TYPICAL QUESTIONS

Aircraft owners sometimes complain about having to re-register aircraft when an amalgamation of corporate entities occurs. Is this really necessary?

Yes - the law requires it. According to a legal opinion received on CARs 202.57(1)(b), when an amalagamtion occurs, the Certificate of Registration is cancelled. It is irrelevant that the new corporation may have the same name as one of the amalgamated corporations. In the eyes of the law, it is a new corporation. If there is a new corporation number which has been assigned by the province, for example, this is a signal that it is, indeed, a new coporation and re-registration is required.

Similarly, in the case of two unincorporated businesses owned by the same person, who then decides to incorporate and transfer the aircraft to that corporation, there would again be a transfer in legal custody and control requiring a change in registration.

The only way that a change would not be required would be if two separate components of the same corporation were joined together in a corporate reorganization. If a new corporation number has been assigned, however, this is a "flag" that it is something other than a coporate reorganization.

How can I transfer ownership of an aircraft which I have inherited? The owner is dead and cannot sign the bill of sale!

If someone has inherited an aircraft and:

  1. wants to register it in their name, they would need to provide Transport Canada with a copy of the will or other legal document showing that they inherited the aircraft and meet all other registration requirements as per usual;

  2. wants to sell it to a third party, Transport Canada requires a copy of the will or other legal document and the bill of sale which would be signed by the person who inherited the aircraft. All other registration requirements would need to be met as per usual.

What should the registration date in CCARCS be if a Temporary Certificate of Registration has been issued for a new owner and has expired (i.e. 3 months have lapsed) and the Continuing Certificate of Registration is being issued?

In this instance, the registration date in CCARCS should be the date that you are issuing the Continuing Certificate of Registration.

What should the registration date in CCARCS be if a Temporary Certificate of Registration has been issued and has not expired (i.e. 3 months have not lapsed) and the Continuing Certificate of Registration is being issued?

In this instance, the registration date in CCARCS should be the issue date of the Temporary Certificate of Registration because there has been no expiration of the Temporary and no "break" in time between the issuance of the Temporary and the Continuing Certificate of Registration. (amended 2000/06/06)

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