Our firm has been a strong advocate for the International Registry (IR) since it entered force in 2006. The IR adds trustworthiness and security to aircraft transactions, protecting the financial interests of aircraft around the world.
Since the inception of the International Registry, Gilchrist Aviation Law has sought to provide consistent feedback regarding the practical use of the IR and its online database. We have put together a list of ideas for further improvement of the IR based on the daily use from the Professional User Entities at our firm. Additionally, our firm sought input from other title law firms and title companies that use the IR for similar purposes.
It should be noted that our recommendations to the International Registry are not intended as complaints or critiques of the IR's effectiveness, but are merely suggestions for how the IR can continue to improve further. Our desire is that these ideas can assist the developers of the IR in making it a more efficient global tool.
Extend the time of how long before the website logs you out of the certificate.
Allow the main PUE to be able to unblock accounts that have been locked out without contacting the IR.
Extend the number of attempts of getting the password correct to more than two (2) times.
Now that the TUEs are associated with the Administrator main account, allow the ability to use the credit on the PUE account when making name changes, mergers, or renewals to TUEs that are associated with the PUE account.
Reduce the number of times the OTP must be entered.
Priority Search Certificate (PSC)
Sort PDFs from search results by the order searched instead of numerical order.
Mark "Discharged by File Number __" on the registration PSC if an interest is discharged.
Allow simultaneous downloads of multiple pages of info searches.
Make the "Entity View" also show who the TUE for the controlled entity is.
Make entity State of Formation and Address available when a PUE user is searching for an entity to verify if the TUE is the same.
Make the "Entity View" also show the expiration date of the TUE.
Make registrations editable once in the Closing Room, if the Closing Room is unlocked.
Create an 'undo' feature for when you move/add/edit the closing room
Include the State of Registry in Preregistration Reports.
Add the ability to click on the Ref No. from the AEP tab to see the AEP Code.
Fix the display re-adjustment that occurs after entering the AEP code in the AEP tab.
Add more information to each registration regarding the consent/active nature of each party.
Add the ability to be able to track the status of all parties involved in a Closing Room before the Closing Room locks.
Trigger email notifications when all parties have consented to the locked Closing Room
Create the ability to bulk upload discharges.
When making fractional registrations, add the ability to list equipment once, list the seller, then list multiple purchasers and their percentages all at one time.
Automatically copy the administrator applying for a TUE on the email to the backup contact.
More lenient acceptance of backup contact's reply-to emails by accepting forwarded emails or a backup's reply to the administrator.
Find ways to limit the TUE approval process to no later than 48 hours after application.
Develop a tracking system for TUE applicants that enables users to see the status of TUE approvals. Specifically, what is pending, if the backup contact is outstanding, or if there is a question on documentation. The tracking system would allow applicants to see, on our end, what the status of the application or name change is without having to reach out to the registry.
Simplify the process of accepting digital signatures.
Implement a procedure for merging banks that have not been "fully merged or acquired" by a surviving bank, but the surviving bank has simply purchased the aircraft loan portfolio from a failed bank, and the failed (or "merging bank") is still in business under its old name.
Allowing the use of the same email (example: IR@abco.com) but switching who is the administrator for that account. That way if a person changes roles or leaves companies you can still use the designated IR email.
Adding the ability to see the name of the entity without having to close the filter box after every MSN search when checking for PUE.
Include the email address in the information of the PUE user when sending PUE authorization request emails.
Set the amount of time that PUE authorization is automatically revoked from users - for example, 90 days or 6 months.
Correct old international interests that were assigned to another entity but were not properly discharged at the time.
Add the ability to remove a filing that is done in error from appearing on the PSC without it showing as "Amended" or "Discharged" as long as the user can prove the registration was completed by error.
Emails from the International Registry
Eliminate duplicate emails to PUE/TUE and reduce the volume of emails received from the IR.
Include the name of the parties involved and the MSN of equipment in the subject line.
When a registration has been initiated for consent (not in a Closing Room), allow administrators on the email (International Registry - Registration Consent - Action Required) to see who has initiated the registration.
When receiving Help Desk acknowledgment emails, tie the ticket number back to the original help request email. This allows viewers to quickly determine what entity the help request is related to.