Direct Answer — Truth-in-Leasing Under 14 CFR §91.23
14 CFR §91.23 requires the parties to a lease or conditional sales contract involving a U.S.-registered large civil aircraft (more than 12,500 pounds maximum certificated takeoff weight, per the §1.1 definition) entered into after January 2, 1973 to execute a written agreement containing a truth-in-leasing clause — in large print, as a concluding paragraph immediately preceding the signature space — that identifies the regulations under which the aircraft was maintained and inspected during the preceding 12 months and names, with address and signature, the person responsible for operational control. Before anyone operates under the lease, §91.23(c) adds three more conditions: a copy must be mailed to the FAA Aircraft Registration Branch in Oklahoma City within 24 hours of execution, a compliant copy must be carried in the aircraft, and the responsible Flight Standards office must be notified at least 48 hours before the first flight under the lease, unless that office authorizes otherwise. A wet lease — defined in §110.2 as providing an entire aircraft and at least one crewmember — normally leaves operational control with the lessor, who then generally needs operating authority; a dry lease transfers the aircraft alone, and the lessee must genuinely exercise operational control. The trap: the FAA judges who actually controls the flights, not what the document is titled.
Truth-in-leasing is the easy part. Operational control is the part that ends careers.
The clause, the filing, the copy aboard, and the notice are mechanical — miss them and you have a documentation violation. The deeper exposure is a dry lease that functions as a charter: if the lessor keeps supplying the crew and running the flights, the FAA treats the arrangement as an uncertificated commercial operation regardless of what the lease says. That is why §91.23(a)(2) forces a named person to sign, in large print, as responsible for operational control. See the companion guide on what operational control actually means.
What §91.23 Actually Requires — The Clause, Word by Word
14 CFR §91.23(a) applies to the parties to a lease or contract of conditional sale involving a U.S.-registered large civil aircraft entered into after January 2, 1973. They must execute a written lease or contract and include a truth-in-leasing clause — in the rule's own words, "as a concluding paragraph in large print, immediately preceding the space for the signature of the parties." Placement and typography are part of the requirement: a compliant clause cannot hide in the definitions section in nine-point type. It must be the last thing each party reads before signing.
The clause must contain three things with respect to each aircraft covered:
(a)(1) — Maintenance and inspection history, certified
Identification of the Federal Aviation Regulations under which the aircraft has been maintained and inspected during the 12 months preceding execution, plus certification by the parties regarding the aircraft's compliance status with applicable maintenance and inspection requirements for the operation to be conducted under the lease. Practically, this means naming the inspection regime the aircraft has actually been on — for example a part 91 inspection program or a certificate holder's maintenance program — and being able to back the certification with records. If the aircraft is moving from part 91 maintenance to a part 135 operation, this is where the gap surfaces.
(a)(2) — A named, signing person responsible for operational control
The name and address (printed or typed) and the signature of the person responsible for operational control of the aircraft under the lease, plus certification that each person understands that person's responsibilities for compliance with applicable Federal Aviation Regulations. This is the heart of the rule. One identified person puts a signature against the statement that they — not the other party, not an ambiguous management company — hold authority over the flights. In an enforcement case or an accident investigation, this signature is one of the first documents pulled.
(a)(3) — The Flight Standards explanation statement
A statement that an explanation of factors bearing on operational control and pertinent Federal Aviation Regulations can be obtained from the responsible Flight Standards office. The FAA wants the parties to know, on the face of the document, that they can ask the regulator what operational control means before they sign — which also removes the later defense that nobody understood the allocation.
What counts as a lease — the §91.23(e) definition
Section 91.23(e) defines the term for this section, verbatim:
"For the purpose of this section, a lease means any agreement by a person to furnish an aircraft to another person for compensation or hire, whether with or without flight crewmembers, other than an agreement for the sale of an aircraft and a contract of conditional sale under section 101 of the Federal Aviation Act of 1958."
Two consequences follow. First, both wet and dry leases are covered — the definition expressly includes agreements with or without flight crewmembers. Second, the trigger is compensation or hire in any form, not a formal document titled Lease. Cost-sharing arrangements, management arrangements with use rights, and exchange-of-time deals involving large aircraft all deserve a §91.23 review before the first flight.
Who is exempt — §91.23(b)
The paragraph (a) requirements — and with them the paragraph (c) filing, carriage, and notice obligations, which attach only to leases to which paragraph (a) applies — do not apply in three situations:
- The party to whom the aircraft is furnished is a foreign air carrier or a certificate holder under part 121, 125, 135, or 141 (§91.23(b)(1)(i)). Leasing a large aircraft onto a certificate is exempt — the FAA already supervises operational control there through the certificate.
- The party furnishing the aircraft is a foreign air carrier, a person operating under part 121, 125, or 141, or a person operating under part 135 with authority to engage in on-demand operations with large aircraft (§91.23(b)(1)(ii)). Note the asymmetry: an ordinary part 135 operator qualifies as an exempt lessee under (b)(1)(i), but as a lessor it is exempt only with on-demand large-aircraft authority.
- A contract of conditional sale where the aircraft has not been registered anywhere prior to execution — except as a new aircraft under a dealer's aircraft registration certificate issued in accordance with §47.61 (§91.23(b)(2)).
Is the filed lease public? §91.23(d) says no.
The copy furnished to the FAA under paragraph (c) is commercial or financial information obtained from a person — it is "privileged and confidential" and will not be made available for public inspection or copying under 5 U.S.C. 552(b)(4), unless the lease is recorded with the FAA under part 49 (the recording system used to perfect interests in aircraft). If your financing requires part 49 recording, understand that the recorded instrument is no longer shielded by §91.23(d).
Primary regulations cited in this section: 14 CFR §91.23 (truth-in-leasing), 14 CFR §1.1 (definitions: large aircraft, operational control).
Wet Lease vs Dry Lease — One Defined Term, One Industry Term
Only one of these terms is actually defined in the regulations. 14 CFR §110.2 defines a wet lease as "any leasing arrangement whereby a person agrees to provide an entire aircraft and at least one crewmember." Dry lease appears nowhere in §110.2 or §1.1 — it is the industry and FAA-guidance shorthand for the opposite arrangement: the aircraft alone, no crew. That asymmetry matters, because the defined term carries the regulatory weight: once the lessor provides even one crewmember with the aircraft, the arrangement is a wet lease, and the operational-control presumption shifts to the lessor.
Wet Lease — defined in §110.2
- Lessor provides the entire aircraft plus at least one crewmember
- Lessor normally retains operational control of the flights
- Providing aircraft + crew for compensation generally requires air carrier / commercial operator certification — in practice, the lessor needs operating authority
- For large aircraft, §91.23 applies unless a (b) exemption fits — and the (b)(1)(ii) lessor exemptions cover certificated carriers precisely because wet-leasing is their business
Dry Lease — industry term, not defined in §110.2
- Lessor provides the aircraft only — no crew
- Lessee supplies and pays its own flight crew and exercises operational control
- Lessee can operate under part 91 where the operation qualifies (its own use, not carriage of persons or property for compensation)
- For large aircraft, the §91.23 clause, 24-hour filing, copy aboard, and 48-hour notice all apply to the lessee
The litmus test is never the title page. A document captioned Dry Lease under which the lessor's pilots fly every trip is a wet lease in substance. A genuinely dry lease can still fail if the crew, while nominally chosen by the lessee, is in practice supplied and scheduled by the lessor — the classic pattern FAA guidance flags when one aircraft is dry-leased to many lessees who all somehow use the same pilots. The FAA's truth-in-leasing advisory circular, AC 91-37B, is guidance rather than regulation, but it walks through these arrangements and the factors bearing on who holds operational control; it is worth reading before structuring any lease.
The subpart F cousins: time sharing, interchange, joint ownership
For large airplanes, turbojet-powered multiengine airplanes, and fractional program aircraft in operations not involving common carriage, 14 CFR §91.501 recognizes several arrangements that are, structurally, leases with crew under limited-compensation rules:
Time sharing agreement — §91.501(c)(1)
An arrangement whereby a person leases his airplane with flight crew to another person, and no charge is made for the flights conducted under that arrangement other than those specified in paragraph (d) of that section.
Interchange agreement — §91.501(c)(2)
An arrangement whereby a person leases his airplane to another person in exchange for equal time, when needed, on the other person's airplane, with charges limited to the difference in owning, operating, and maintaining costs between the two airplanes.
Joint ownership agreement — §91.501(c)(3)
An arrangement whereby one registered joint owner employs and furnishes the flight crew, and each registered joint owner pays a share of the charge specified in the agreement.
Because each of these involves furnishing an aircraft for some form of compensation — and §91.23(e) sweeps in any such agreement, with or without crew — these arrangements involving a large civil aircraft are in practice subject to the truth-in-leasing clause, the 24-hour filing, the copy aboard, and the first-flight notice. Operators in fractional programs face an additional records layer entirely — see the Part 91K fractional ownership compliance records guide.
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Related Aviation Compliance Guides
The Records and Filings — Four Obligations, In Order
Section 91.23(c) is structured as an operating prohibition: no person may operate a large civil aircraft of U.S. registry subject to a covered lease unless three conditions are met — on top of the executed written lease itself. Treat them as a sequence with deadlines, because two of them have clocks attached.
- 1
Execute a written lease containing the truth-in-leasing clause
The clause must be a concluding paragraph in large print immediately preceding the signature space, containing the (a)(1) maintenance/inspection identification and certification, the (a)(2) operational-control designation with name, address, and signature, and the (a)(3) Flight Standards explanation statement. An oral lease of a large civil aircraft cannot comply — the rule requires a written agreement.
- 2
Mail a copy to the FAA Registry within 24 hours of execution
Under §91.23(c)(1), the lessee or conditional buyer — or the registered owner if the lessee is not a U.S. citizen — must mail a copy of the compliant lease to the Aircraft Registration Branch, Attn: Technical Section, P.O. Box 25724, Oklahoma City, OK 73125, within 24 hours of execution. Keep dated proof of the mailing with the lease file; the 24-hour clock runs from execution, not from the first flight.
- 3
Put a compliant copy in the aircraft — and keep it there
Under §91.23(c)(2), a copy of the compliant lease must be carried in the aircraft and made available for review upon request by the Administrator. On a ramp inspection it sits in the same practical category as the airworthiness certificate and registration — paperwork the inspector expects on board. Crews should know where it is.
- 4
Notify the responsible Flight Standards office at least 48 hours before the first flight
Under §91.23(c)(3), the lessee or conditional buyer (or registered owner, for a non-citizen lessee) must notify the responsible Flight Standards office by telephone or in person. Unless otherwise authorized by that office, the notification must come at least 48 hours before takeoff of the first flight under that lease, and must give the location of the airport of departure, the departure time, and the registration number of the aircraft. Make a contemporaneous memo — who called, when, which office, who answered — because the rule creates no FAA-issued receipt.
The lease file — what a complete one contains
Section 91.23 states no numeric retention period. The discipline is driven by exposure instead: operational-control questions surface after incidents, audits, and insurance claims — often long after the flight. A defensible lease file holds:
Executed lease with the clause
The signed agreement with the large-print truth-in-leasing clause immediately preceding the signatures — plus every amendment and extension, each of which deserves the same §91.23 treatment.
Proof of the 24-hour mailing
Dated mailing evidence to the Aircraft Registration Branch in Oklahoma City. Without it, you cannot later show the (c)(1) condition was met before operations began.
First-flight notification record
A contemporaneous memo of the §91.23(c)(3) call or visit: date, time, office, person notified, and the three data points given — departure airport, departure time, registration number.
Maintenance/inspection support for (a)(1)
The records behind the clause's certification: which regulations the aircraft was maintained and inspected under for the preceding 12 months. For a part 91 airplane that typically means the inspection program records — see the annual inspection requirements guide below.
Crew employment or services agreements
Who employs, schedules, and pays the pilots is central evidence of who exercises operational control. In a dry lease, these agreements should run to the lessee — not back to the lessor.
Operating-cost and insurance documentation
Fuel, maintenance, and hangar invoices showing who bears the operating costs, plus insurance certificates naming the party in control. In practice these are the documents an investigator uses to test whether the lease label matches reality.
The copy-aboard requirement pairs naturally with the rest of the onboard document stack — see the ARROW documents guide for what else must be in the aircraft. For the maintenance history behind the (a)(1) certification, see the §91.409 annual inspection requirements and the broader Part 91 aircraft records requirements.
The Operational-Control Trap — Where Leases Become Illegal Charters
Operational control is defined in 14 CFR §1.1 — with respect to a flight, it means "the exercise of authority over initiating, conducting or terminating a flight." Eleven words, and nearly every leasing enforcement case turns on them. The §91.23(a)(2) clause forces the parties to name the person who holds that authority; the FAA then tests whether the facts match the name.
In a genuine dry lease, the lessee holds the authority: it decides whether a trip happens, where the aircraft goes, and when it stops; it selects, employs or directly contracts, and pays the flight crew; it bears the operating costs and the risk. FAA guidance — including the truth-in-leasing advisory circular AC 91-37B — frames the inquiry around practical questions of exactly that kind, and inspectors in practice look at the same things:
Looks like a real dry lease
- Lessee decides whether, when, and where the aircraft flies
- Lessee hires and pays the pilots directly — from any qualified source it chooses
- Lessee pays fuel, maintenance, hangar, and insurance as the operator
- Lessee’s named person signed the (a)(2) operational-control designation — and behaves like it
- Lease rate reflects the aircraft alone, not per-trip charter pricing
Looks like a charter wearing a dry-lease costume
- Lessor (or its affiliate) supplies and schedules the crew on every flight
- Lessee must use the lessor’s pilots — no real freedom to crew the aircraft
- Pricing is per flight hour all-in, structured like charter
- Multiple short-term lessees rotate through the same aircraft and the same crew pool
- The person who signed as responsible for operational control never actually makes a flight decision
When the second column describes the facts, the FAA treats the lessor as the operator — a person carrying others for compensation or hire without the certificate that kind of operation requires. The pilots flew what was functionally an on-demand operation outside any certificate, training program, or drug-and-alcohol program. Illegal-charter enforcement has been a sustained FAA priority in recent years, and sham dry leases sit at the center of it.
What the exposure looks like
- Civil penalties. Under 49 U.S.C. 46301 as adjusted by 14 CFR §13.301, for violations occurring on or after December 30, 2024 the maximum runs up to $75,000 per violation for entities other than individuals or small businesses, and up to $1,875 per violation for individuals and small business concerns. A pattern of flights can multiply the counts.
- Certificate action against the pilots. Pilots who fly what turns out to be an uncertificated commercial operation face FAA certificate action personally — suspension or revocation proceedings — even if they believed the lease paperwork.
- Insurance jeopardy. After an incident, insurers investigate who held operational control. A lease that misstates control — or filings that were never made — gives a carrier grounds to contest coverage. This is a practical consequence, not a CFR citation, and it is frequently the most expensive one.
- Documentation violations stack on top. Operating without the clause, the 24-hour filing, the copy aboard, or the 48-hour notice are each independent §91.23 failures — easy for an inspector to establish from records alone.
Operational control is also the load-bearing concept across certificated operations — the same §1.1 definition governs who may exercise it on a part 135 certificate, which is why a charter operator can never hand control to a broker or a customer. For the certificated-side analysis, read what operational control means in Part 135; for how inspectors probe it during oversight, see preparing for a Part 135 FAA surveillance audit.
The Part 135 Intersection — Leasing Aircraft Onto a Certificate
Most growing charter operators lease at least some of their fleet, and §91.23(b)(1)(i) exempts those leases from the truth-in-leasing clause: when the party to whom the aircraft is furnished is a part 121, 125, 135, or 141 certificate holder (or a foreign air carrier), paragraph (a) does not apply. The FAA does not need a large-print clause to know who controls flights on a certificate — operational control is already locked to the certificate holder through its authorizations and oversight.
What replaces it is a different documentary regime under 14 CFR §135.25:
Exclusive use of at least one aircraft — §135.25(b)
Each certificate holder must have the exclusive use of at least one aircraft that meets the requirements for at least one kind of operation authorized in its operations specifications. For each kind of operation without an exclusive-use aircraft, the operator must have available for use under a written agreement — including arrangements for performing required maintenance — at least one aircraft meeting the requirements for that kind of operation.
What exclusive use means — §135.25(c)
A person has exclusive use when it has the sole possession, control, and use of the aircraft for flight as owner, or a written agreement — again including maintenance arrangements — in effect whenever the aircraft is operated, giving that possession, control, and use for at least 6 consecutive months. A month-to-month handshake does not establish exclusive use; the 6-consecutive-month written term is the floor.
The aircraft must be in the OpSpecs before revenue flights — FAA practice
In practice, every aircraft operated under the certificate is listed in the operator's operations specifications, and adding a leased tail means working with your certificate-holding office to amend them — with conformity, maintenance program incorporation, and records review along the way. The lease agreement is one exhibit in that package; the maintenance arrangements language required by §135.25 is what FSDOs read most closely.
The records ripple outward from there. A leased aircraft joins the operator's maintenance program and recordkeeping system — see Part 135 maintenance recordkeeping and CAMP requirements — and its lease, conformity, and OpSpec paperwork belongs in the same audit-ready system as the rest of the certificate file. For the full documentary picture, start with what records a Part 135 operator must keep and the operations specifications explained guide. And because operational control on a certificate runs through identified management personnel, the required management personnel qualifications sit directly behind every leased-aircraft decision.
FileFlo as the Lease Records Layer
FileFlo is a compliance document intelligence platform — the proof layer for the paperwork this article describes. It does not draft leases, determine operational control, or file anything with the FAA. What it does is make sure that when an inspector, an insurer, or a buyer asks for the lease file, the lease file exists, is complete, and is findable in seconds.
- Classifies and indexes lease agreements, amendments, crew services agreements, and conformity paperwork against the right aircraft and the right requirement
- Tracks lease expiration and renewal dates — including the §135.25(c) 6-consecutive-month exclusive-use window — with alerts before terms lapse
- Keeps the proof-of-mailing record and the first-flight notification memo linked to the lease they support
- Surfaces the operational-control designation page so the named person is never a mystery during an audit
- Generates an audit-ready lease binder on demand — lease, filings, notices, crew agreements, and supporting maintenance history in one organized package
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Frequently Asked Questions
What must the truth-in-leasing clause under 14 CFR §91.23 contain?
Three elements, set out as a concluding paragraph in large print immediately preceding the space for the signatures of the parties. Per §91.23(a)(1): identification of the Federal Aviation Regulations under which the aircraft has been maintained and inspected during the 12 months preceding execution of the lease, plus certification by the parties regarding the aircraft's compliance status with applicable maintenance and inspection requirements for the operation to be conducted. Per §91.23(a)(2): the name and address (printed or typed) and the signature of the person responsible for operational control of the aircraft under the lease, plus certification that each person understands that person's responsibilities for compliance with applicable Federal Aviation Regulations. Per §91.23(a)(3): a statement that an explanation of factors bearing on operational control and pertinent Federal Aviation Regulations can be obtained from the responsible Flight Standards office. A lease missing any of the three elements — or burying the clause mid-document in ordinary type — does not comply.
Which aircraft leases does the §91.23 truth-in-leasing rule apply to?
Leases and conditional sales contracts involving U.S.-registered LARGE civil aircraft — aircraft of more than 12,500 pounds maximum certificated takeoff weight under the 14 CFR §1.1 definition — entered into after January 2, 1973. Section 91.23(e) defines a lease broadly: any agreement by a person to furnish an aircraft to another person for compensation or hire, whether with or without flight crewmembers. So both wet and dry leases of large aircraft are covered. Paragraph (b) exempts: leases where the party receiving the aircraft is a foreign air carrier or a certificate holder under part 121, 125, 135, or 141; leases where the party furnishing the aircraft is a foreign air carrier, a person operating under part 121, 125, or 141, or a part 135 operator with authority to engage in on-demand operations with large aircraft; and conditional sales of aircraft never previously registered (except new aircraft under a dealer's certificate per §47.61). For aircraft at or under 12,500 pounds, the clause and filing requirements do not apply — but the operational-control analysis behind them absolutely still does.
What is the difference between a wet lease and a dry lease?
A wet lease is defined in 14 CFR §110.2 as any leasing arrangement whereby a person agrees to provide an entire aircraft and at least one crewmember. Because the lessor supplies the crew, the lessor normally keeps operational control of the flights — and a person providing aircraft plus crew to others for compensation is, in most fact patterns, conducting the kind of operation that requires air carrier or commercial operator certification. A dry lease transfers the aircraft alone: no crew. The lessee supplies its own pilots, exercises operational control, and — if the operation qualifies — can fly under part 91. Note the asymmetry: wet lease is a defined regulatory term; dry lease is not defined in §110.2 or §1.1. It is industry and FAA-guidance shorthand for an aircraft-only lease. The label on the document does not decide anything — the FAA looks at who actually controls the flights.
What filings and records does §91.23(c) require before operating a leased large aircraft?
Three operating conditions apply to a large civil aircraft subject to paragraph (a). First, the lessee or conditional buyer — or the registered owner if the lessee is not a U.S. citizen — must mail a copy of the compliant lease to the FAA Aircraft Registration Branch, Attn: Technical Section, P.O. Box 25724, Oklahoma City, OK 73125, within 24 hours of its execution (§91.23(c)(1)). Second, a copy of the compliant lease must be carried in the aircraft and made available for review upon request by the Administrator (§91.23(c)(2)). Third, the responsible Flight Standards office must be notified by telephone or in person at least 48 hours before takeoff in the case of the first flight under that lease — unless that office authorizes otherwise — including the location of the airport of departure, the departure time, and the registration number of the aircraft (§91.23(c)(3)). No person may operate the aircraft under the lease until all three are satisfied.
What is operational control and why is it the trap in aircraft leasing?
Operational control is defined in 14 CFR §1.1 — not in part 110 — as the exercise of authority over initiating, conducting or terminating a flight. In a genuine dry lease, the lessee holds that authority: it decides whether, when, and where the aircraft flies, selects and employs (or directly contracts) the flight crew, and bears the operating costs and risk. The trap arises when the paperwork says dry lease but the lessor in fact runs the flights — supplies the pilots, controls scheduling, manages the aircraft, and prices the arrangement like a charter. In that case the lessor is exercising operational control and, in the FAA's view, conducting a commercial operation without the required certificate. The §91.23(a)(2) clause exists precisely to force the parties to name, in large print above the signature line, the one person responsible for operational control — so nobody can later claim confusion.
What happens if the FAA decides a dry lease is really an illegal charter?
The FAA evaluates substance over form. If the facts show the lessor retained operational control while collecting compensation, the agency treats the flights as uncertificated commercial operations. Consequences in practice: civil penalties under 49 U.S.C. 46301 — under the current inflation-adjusted schedule in 14 CFR §13.301, for violations occurring on or after December 30, 2024, up to $75,000 per violation for entities other than individuals or small businesses, and up to $1,875 per violation for individuals and small business concerns; certificate action against pilots who flew the operations; and scrutiny of everyone who arranged the flights. Each non-compliant flight can add to the count. Separately, insurers routinely investigate who held operational control after an incident, and a lease that misstates control can put coverage in question. Illegal-charter enforcement has been a sustained FAA priority in recent years, and sham dry leases are one of its central targets.
Does truth-in-leasing apply when an aircraft is leased to a Part 135 operator?
Generally no — §91.23(b)(1)(i) exempts a lease when the party to whom the aircraft is furnished is a certificate holder under part 121, 125, 135, or 141 (or a foreign air carrier). The logic in practice: the FAA already supervises operational control on a certificate through operations specifications and surveillance. But the document obligations do not disappear; they change shape. Under 14 CFR §135.25(b), a certificate holder must have exclusive use of at least one aircraft, and for each kind of operation without an exclusive-use aircraft it must have a written agreement — including arrangements for performing required maintenance — covering at least one qualifying aircraft. Under §135.25(c), exclusive use means sole possession, control, and use for flight as owner, or a written agreement (including maintenance arrangements) in effect whenever the aircraft is operated, giving that possession, control, and use for at least 6 consecutive months. In practice the leased aircraft must also be reflected in the operator's operations specifications before revenue flights.
How long should aircraft lease records be kept, and are they public once filed with the FAA?
Section 91.23 itself states no numeric retention period — it requires the copy carried in the aircraft to be available for review upon request by the Administrator for as long as operations occur under the lease. Sensible practice is to keep the executed lease, proof of the 24-hour mailing, and a contemporaneous record of the 48-hour Flight Standards notification for the life of the lease plus your normal document-retention horizon, because operational-control questions tend to surface months or years later (after an incident, an audit, or an insurance claim). On confidentiality: under §91.23(d), the copy furnished to the FAA is commercial or financial information obtained from a person — it is privileged and confidential and will not be made available for public inspection or copying under 5 U.S.C. 552(b)(4), unless the lease is recorded with the FAA under part 49.
If the FAA asked for your lease file tomorrow, could you produce it?
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Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 10, 2026. FileFlo is a compliance document platform, not a law firm — this article is a compliance-document perspective, not legal advice. Have an aviation attorney review any aircraft lease, and verify filing logistics with the FAA Aircraft Registration Branch and your responsible Flight Standards office.