Pre-close diligence
Heavy-check exit repair-approval records review for acquisition teams
Acquisition teams buying an aircraft as it exits heavy check inherit every repair the visit added. This review examines the repair and alteration records generated during the check, from damage reports through disposition, the approved data cited, and the return-to-service entries, and it reconciles the results against the repair map the seller supplies. Endeavor Elements runs it before the purchase closes, while the pricing and the condition-precedent list can still move. The buyer receives a verified repair picture, a register of repairs whose approval basis is thin, and the evidence requests to put to the seller.
When this review is needed
- The purchase agreement times closing to check exit and the repair paperwork is still being assembled by the MRO.
- The seller's repair map predates the visit and nothing confirms it reflects what the check just added.
- Structural findings during the check were dispositioned quickly to hold the schedule, and the approval basis was never scrutinized.
- The buyer intends to lease the aircraft out, and the next lessee's records standard will retest every repair the file contains.
The problem
A heavy check is where an airframe's damage history surfaces and gets fixed, and the paperwork trails the metal by weeks. A buyer closing at exit is asked to accept a repair file the shop is still compiling, against a repair map that may not include this visit at all. The diligence window and the check schedule end at roughly the same moment, which favors the party that already knows what the records say.
What gets reviewed
- Damage reports raised during the visit and the disposition each one received
- The approval basis cited for each repair, whether SRM, OEM disposition, or DER-approved data
- Major-repair classifications and the FAA Form 337 or equivalent filings they require
- Return-to-service entries covering the repair work performed at the check
- The seller's repair map reconciled against the repairs the visit added
- Alterations embodied during the visit and the STC or other approval each relies on
Scope this review
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What gets validated
- Every damage report in the visit paperwork reaches a documented disposition, with none left open or unresolved
- Each repair outside SRM limits cites approved data that actually covers the damage location and extent
- Major repairs carry the classification and filing the operating rule requires
- The repair map, once updated, accounts for every repair the check performed
- Return-to-service entries name the repair work performed and trace to the approvals behind it
Evidence normally required
- The visit's non-routine cards and damage reports as compiled by the MRO
- Repair dispositions with the approved data packages they cite
- The seller's current repair map and any prior structural repair listing
- FAA Form 337 filings or the equivalent alteration and repair submissions
- The draft purchase agreement's records conditions, if the buyer will share them
Common discrepancies
- A repair executed to a disposition that covers a smaller damage area than the report describes
- Repair-map entries missing for repairs the visit demonstrably performed
- A repair recorded as minor that meets the criteria for major classification and its filings
- Dispositions citing engineering support that was never delivered into the records
What is at stake
A repair accepted at closing without its substantiation becomes the buyer's problem at the next transaction, when a lessee's reviewer or a later buyer asks for the approved data behind it. Reconstructing a disposition after the shop has archived the visit is slow, and a repair that cannot be substantiated is priced against the owner every time the aircraft trades.
How the work runs
Build the repair population
Compile every repair and alteration the visit produced from non-routine cards, damage reports, and shop paperwork.
Verify each approval basis
Match dispositions and approved data to the damage actually described, and check classifications and filings.
Reconcile the repair map
Mark up the seller's map with the visit's additions and any pre-existing entries the records contradict.
Report into the deal
Deliver the findings ranked by transaction impact, with the evidence request for each open item.
What the buyer receives
- A repair-by-repair verification table covering everything the visit added
- A register of repairs with weak or missing approval bases, ranked by transaction impact
- A pre-close evidence request list for the seller and the performing MRO
- An updated repair-map markup the buyer can carry into ownership
Who uses the output
- The technical due-diligence lead deciding which findings become conditions precedent
- The investment team pricing repair risk into the deal
- The buyer's records team seeding the post-close baseline
How the work fits into the transaction or program
The review runs inside the diligence window, in parallel with the check's final weeks. Its findings feed the condition-precedent list and the closing adjustments, and its verified repair picture becomes the starting repair map the buyer maintains after title transfers.
Start with a single asset
Organize records and a discrepancy register for diligence.
Jurisdiction-specific considerations
What counts as acceptable approval data differs by registry. A repair substantiated for an FAA-registered airframe under 14 CFR Part 43 may need re-examination if the buyer plans an EASA registration, where the CAMO will apply Part-M expectations to the same file. The review flags repairs whose basis holds under one system and thins under the other.
Regulatory limits
This is a documentation review performed for a commercial decision. It does not approve repairs, classify them on behalf of any authority, issue or validate approved data, or determine airworthiness. Those functions belong to the certificate holders and authorities involved.
What this review does not cover
- Physical or NDT inspection of the repaired structure
- Negotiating the purchase price or the conditions precedent themselves
- Engineering re-substantiation of repairs found lacking approved data
Specific to this review
- Dispositions issued under schedule pressure late in a check are where approval bases run thinnest; the visit's final two weeks deserve the closest read.
- A repair map is only as current as its last disciplined update, and heavy checks are exactly when updates get deferred.
- Buyers hold their maximum evidence leverage before closing; a seller's motivation to chase a missing disposition drops sharply once funds move.
- Classification disputes between minor and major are cheap to resolve before closing and expensive after, because the filing burden lands on whoever owns the aircraft when the question is asked.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
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 MRO is reputable and the check is fresh. Why review the repair records at all?
Shop quality and records quality diverge under schedule pressure, and the buyer answers for the file for as long as it owns the aircraft. The review costs days; a repair without substantiation surfaces at every future transaction until someone pays to fix it.
Relevant glossary terms
Related pages
Where this fits
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