Non-routine card closure review in the deal data room

When this review is needed

• The non-routine register from the last heavy check is posted but the card images behind it are not.
• Structural findings appear in the register and their repair approvals are nowhere in the index.
• A register looks implausibly clean for the check size, suggesting lines were filtered before upload.
• Defects deferred at check exit need proof of later clearance rather than a quiet carry-forward.

The problem

Non-routine cards are the honest record of an aircraft's condition, which is exactly why they arrive in data rooms incomplete. Registers get exported without the cards, dispositions reference engineering orders that were never uploaded, and a defect marked closed may have been transferred to a deferral log living in a different folder tree. Following one defect to its end can mean touching five documents scanned by different people in different years.

What gets reviewed

• The non-routine register reconciled against the card images actually uploaded
• Sampled cards traced from the raising entry through disposition to certified closure
• Dispositions referencing engineering orders, repair drawings, or deferrals followed to those documents
• Structural non-routines matched to repair approvals and any repeat-inspection requirements
• Transfers into the deferred defect log verified for later clearance evidence
• Register completeness judged against check size and fleet-typical find rates

What gets validated

• Each sampled card shows a disposition that a certifying person signed for
• Corrective actions cite the data used, and that data was approved for the application
• Cards dispositioned as repairs connect to the substantiation or approval in the room
• Defects transferred to deferral carry the authorization and the eventual clearing entry
• Register line counts agree with the card sets and with the check's closure documentation

Evidence normally required

• The non-routine registers for the checks in scope
• Uploaded card images and any linked engineering orders or repair files
• The deferred defect log covering the same period
• Data-room index and Q&A access for locating scattered references
• Check completion certificates that assert all non-routines were closed

Common discrepancies

• Registers exported from the maintenance system with statuses the card images contradict
• A repair disposition citing engineering data the room does not contain
• Closure signatures dated before the corrective action the card describes
• Defects that vanish between the register and the deferral log with no clearance entry anywhere

What is at stake

A defect closed on paper without its disposition evidence is an open question about the aircraft's physical state. Structural non-routines without approved repair data can trigger reinspection or re-repair at the next check, and a filtered register that later proves incomplete undermines every representation the seller made about condition.

How the work runs

What the buyer receives

• A closure-trail report showing each sampled defect's path and where it breaks
• Folder-referenced exceptions for the diligence schedule, graded by exposure
• A follow-up request list naming the engineering orders and approvals still needed

Who uses the output

• Due-diligence engineers judging condition risk behind the paper
• Deal counsel framing representations about defect closure
• The buyer's records team preparing the post-closing retrieval effort

How the work fits into the transaction or program

This review pairs naturally with task-card sampling: routine cards prove the planned work, non-routine cards prove what the aircraft actually needed. Findings with structural content route into the repair-records review, deferrals route into the deferred-maintenance review, and the combined exceptions land in one diligence schedule.

Jurisdiction-specific considerations

Both FAA and EASA regimes require maintenance records that state what was done and reference the data used, but the paper trails differ: US repairs lean on 14 CFR 43 entries and, for major work, FAA Form 337 or DER-approved data, while EASA closures reference approved data under Part-145 procedures. The review applies whichever convention the accomplishing organization worked under.

Regulatory limits

The reviewer reports evidence, and only evidence. No finding constitutes an airworthiness determination, an approval of a repair or its data, or a certification decision; those remain with authorized persons and the competent authority.

What this review does not cover

• Inspecting the aircraft to confirm defect rectification physically
• Producing or approving repair data for open dispositions
• Re-running the seller's maintenance system to regenerate registers

Specific to this review

• A suspiciously short non-routine register is itself a finding; heavy checks on mature aircraft reliably generate findings, and their absence usually means filtering.
• Dispositions that read repaired per the SRM still need the chapter and figure, because SRM applicability limits are where marginal repairs fail.
• The deferral log is the escape hatch of check closure; defects moved there at check exit deserve the closest reading.
• Closure certification by the same signature that raised the defect is a process red flag worth a Q&A question, even where rules permit it.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits