Lease return
AD compliance status inside the redelivery binder source set
At redelivery, the AD status list in the binder asserts a compliance position the receiving party will inherit. This review tests that assertion against the binder's own source set: accomplishment records, method-of-compliance references, and the discrepancy register from the return inspection. It is run for the asset manager or incoming operator before the acceptance certificate is signed. Each AD shown complied with but lacking its accomplishment evidence in the binder comes back as an exception with its commercial weight noted.
When this review is needed
- Acceptance is days away and the AD section of the binder has only been checked for presence, never against evidence.
- The status list was generated from the returning operator's system and the binder was assembled separately.
- Repetitive ADs need next-due data the incoming operator's program will rely on from day one.
- Return conditions price open ADs, so the true open population determines money changing hands.
The problem
An AD status list is a database report, and the binder is a document set; nothing forces them to agree. The list may show an AD terminated by a modification whose embodiment record never made the binder, or complied with by an inspection whose card sits in an archive the return does not include. The asset manager reads a clean list over a source set that cannot reproduce it, and the difference only surfaces when someone works each line back to a document, which redelivery timetables rarely allow.
What gets reviewed
- Each AD on the status list traced to accomplishment evidence within the binder source set
- Methods of compliance checked against what the cited record actually documents
- Terminating actions verified through modification or repair embodiment records
- Repetitive ADs checked for last-done evidence sufficient to compute next-due
- Supersedure chains confirmed so status is reported against the current AD revision
- Open ADs reconciled with the discrepancy register and the return-condition pricing
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Send a representative, redacted record set and we will scope the review.
What gets validated
- Every complied-with entry cites a binder document that records the accomplishment
- The method recorded in evidence matches the method claimed on the list
- Alternative methods of compliance are supported by the approval that authorized them
- Last-done values for repetitive ADs reproduce from dated records rather than system entries
- The list is cut against current AD revisions, with superseded numbers mapped forward
Evidence normally required
- The AD status list at its redelivery revision
- The binder source set: accomplishment records, modification records, release documents
- The return discrepancy register and acceptance notes to date
- AMOC approvals and any authority correspondence cited by the list
Common discrepancies
- ADs closed by reference to an SB whose accomplishment paperwork is absent from the binder
- AMOC-based compliance with the approval letter missing
- Repetitive ADs with last-done dates traceable only to the departing operator's system
- Status reported against superseded AD numbers, masking new requirements in the current revision
What is at stake
Signing acceptance against an unevidenced AD list transfers the proof burden to the new holder. When the next authority audit, airworthiness review, or sale asks for accomplishment evidence, the previous operator is gone and contractually finished, and rebuilding the record means chasing a counterparty with no remaining obligation. Repetitive ADs with unsupported last-done dates are the sharpest edge, because the next-due calculation the new program adopts may be wrong in the unconservative direction.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Cut the baseline
Fix the AD revision state at the review date and map superseded numbers on the list forward.
Evidence every closure
Work each complied-with line to its accomplishment document within the binder.
Stress the repetitives
Reproduce last-done and next-due values from dated records.
Issue demands
Deliver the exception list and the document demands while the return conditions still apply.
What the buyer receives
Who uses the output
How the work fits into the transaction or program
AD status is usually the highest-stakes section of the redelivery binder because it carries direct regulatory consequence for the next holder. This review runs inside the acceptance window, while the returning operator still has a contractual duty to produce documents, which is the only period when demand letters cost nothing.
Jurisdiction-specific considerations
The obligation behind the list sits in 14 CFR 39, and 91.417 requires the current AD status with method, date, and next due to travel with the aircraft records. Aircraft moving to an EASA-regime operator will have the same list read under EU 1321/2014 by a CAMO that must be able to evidence it, so the review applies the stricter reading where the destinations differ.
Regulatory limits
The review tests documentary support for the status list. It does not determine AD applicability, approve methods of compliance, perform engineering assessment, or declare the aircraft airworthy; it defines what the binder can and cannot prove at signature.
What this review does not cover
- AD applicability engineering for this serial number beyond what the list asserts
- Negotiation of return-condition compensation
- Physical verification of embodied modifications
Specific to this review
- Demand leverage expires at acceptance: a missing accomplishment record costs a letter before signature and litigation after it.
- Supersedure is the quiet failure mode; a list maintained against old AD numbers can be internally perfect and still wrong.
- AMOC compliance doubles the evidence burden, requiring both the approval and the accomplishment, and binders routinely hold one without the other.
- For repetitive ADs, an unsupported last-done value is worse than a missing one, because it invites a wrong next-due rather than a conservative reset.
Sources
U.S. Government (eCFR). The legal basis for issuing and enforcing Airworthiness Directives on U.S.-registered products.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
The returning operator says the records exist in their archive. Is that enough?
Not for signature. Records outside the binder are records the new holder does not have, and the return conditions typically require delivery. If they exist, the acceptance window is when to convert that claim into delivered documents, because the obligation to produce them ends with the lease.
Relevant glossary terms
Related pages
Where this fits
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