FileFlo vs. ATP CTS:
ATP CTS Tracks the Pilot Training Dates.
FileFlo Holds the §135.21 / §135.293 / §135.351 Audit Binder.
ATP CTS is an aviation crew training records and maintenance publications platform built specifically for Part 135 on-demand air carriers and Part 91 corporate flight departments — pilot training dates under 14 CFR §135.293 competency checks, §135.351 recurrent training, §135.345 PIC/SIC proficiency checks, Part 61 §61.56 flight reviews and §61.57 currency, plus the OEM maintenance publications library the contract Part 145 station references for §43.13 performance compliance. ATP CTS is the records database a chief pilot accesses every week to verify pilot currency before assigning the next 135 leg. FileFlo is a different layer — the compliance document evidence platform the FAA Principal Operations Inspector (POI) pulls during Part 135 surveillance under FAA Order 8900.1 Volume 3 Chapter 18: AI-classifying 600+ document types, holding the §135.21 General Operations Manual file with version history, the signed §135.293 + §135.351 + §135.345 training records, the §61.56 + §61.57 cross-reference, the §135.63 crewmember binder, and the §43.9 + §43.7 maintenance entries from the contract Part 145 station as the one-click FAA-POI-ready audit binder. Together, not versus. Here is the honest side-by-side at a flat $299/mo.
Almost every Part 135 chief pilot and Part 91 corporate flight department director of operations I have spoken with in the last twelve months has had some version of this conversation: "ATP CTS tracks our pilot training dates — every Part 135 pilot's §135.293 competency check, §135.351 recurrent training, §135.345 PIC/SIC proficiency check, plus the Part 61 §61.56 flight review and §61.57 currency. The training-records database is real, the LMS integration works, and we are not going to switch off it. But during our last FAA POI surveillance under 8900.1 Volume 3 Chapter 18, the inspector asked for our §135.21 General Operations Manual revision history with FAA-acknowledgment correspondence going back five years, the signed §135.293 competency check forms with the check airman signatures, the §135.351 recurrent training certificates with the ground-training subjects covered, the §135.345 PIC/SIC proficiency check write-ups, the §61.56 flight review endorsements cross-referenced to the §135.293 IPC, and the §135.63 crewmember binder reconciling every event per pilot per aircraft. ATP CTS shows the dates — but it does not hold the signed §135.293 form, the §135.351 certificate, the §61.56 endorsement, or the §135.63 crewmember file. Is there a software tool that closes the compliance evidence binder gap without replacing what ATP CTS already does well?" ATP CTS is the pilot training records platform where the Part 135 chief pilot and Part 91 corp flight department DO track the dates required under 14 CFR §135.293, 14 CFR §135.351, and Part 61 §61.56 / §61.57. That training-records workflow is the real-time chief pilot surface — it runs every week as pilots fly, it integrates with the training-delivery LMS, and it is the single pane of glass the chief pilot uses to verify a pilot is current before assigning the next 135 leg. FileFlo does not attempt to replace any of that — that is the LMS-style records database, that is the daily chief pilot workflow, and ATP CTS is built specifically for the pilot training records use case. What FileFlo does is the next layer: the compliance document evidence binder under 14 CFR §135.21, 14 CFR §135.63, 14 CFR Part 61, and (for the contract Part 145 maintenance side) 14 CFR §43.9 — the document evidence file the FAA POI/PMI pulls during a Part 135 surveillance event. ATP CTS shows the dates the §135.293 IPC and §135.351 recurrent were completed; FileFlo holds the signed §135.293 form, the §135.351 certificate, the §61.56 endorsement, and the §135.63 crewmember file behind them.
This page is not a takedown of ATP CTS. The ATP CTS pilot training records workflow is built specifically for the crew-currency tracking use case — the database that tells a chief pilot which pilots are current for the next 135 leg, the LMS integration that delivers the §135.351 ground training, the maintenance publications library mechanics search for current-revision OEM manuals — and that is genuinely the right records-database surface for the daily Part 135 chief pilot and the Part 91 corp flight department DO. Operators who rely on ATP CTS for daily pilot training records access should keep ATP CTS. The honest question is whether ATP CTS is also the right tool for the compliance document evidence binder the FAA POI/PMI pulls during an FAA Order 8900.1 Volume 3 Chapter 18 (or Volume 6) surveillance event — and the answer for most Part 135 + Part 91 operators is that the compliance-evidence side of the workflow is out of scope for ATP CTS (because ATP CTS is built for training-records tracking, not the signed regulatory-compliance archive) and is the specific gap FileFlo closes. The right operating model for most Part 135 + Part 91 operators is ATP CTS for the pilot training records database + FileFlo at $299/mo for the compliance document evidence layer. The two products are complements, not substitutes, and the combined operating cost is dramatically lower than the enterprise aviation compliance platform alternatives.
Quick Verdict
- Compliance document evidence binder for FAA POI surveillance (8900.1 Vol 3 Ch 18)
- 14 CFR §135.21 GOM/MOM file with version history + FAA-ack correspondence
- 14 CFR §135.293 competency check signed forms + check airman signatures
- 14 CFR §135.351 recurrent training completion certificates + subject coverage
- 14 CFR §135.345 PIC/SIC proficiency check signed write-ups
- Part 61 §61.56 flight review + §61.57 currency cross-reference to §135.293
- 14 CFR §135.63 crewmember recordkeeping binder per pilot + aircraft
- 14 CFR §43.9 + §43.7 maintenance entry storage from contract Part 145 station
- AI document classification across 600+ aviation compliance document types
- Flat $299/mo unlimited pilots + aircraft — no per-pilot subscription inflation
- 5-day self-serve trial — live in minutes, no implementation
- Pilot training records database (event dates by crewmember)
- LMS integration for §135.351 ground-training delivery
- Chief pilot weekly currency check before assigning next 135 leg
- Multi-aircraft-type training-records access for Part 135 + Part 91
- OEM maintenance publications library for §43.13 acceptable-data source
- Multi-base Part 135 operator user access control
- Training-delivery + records-tracking single-vendor consolidation
The honest answer for most Part 135 / Part 91 operators on ATP CTS: keep ATP CTS for the pilot training records database the chief pilot accesses every week + add FileFlo at $299/mo for the compliance document evidence layer the FAA POI pulls. The two products are complements — ATP CTS shows the §135.293 + §135.351 + §61.56 dates, FileFlo holds the signed forms + endorsements + §135.63 crewmember binder behind them.
Feature-by-Feature Comparison
Based on publicly available ATP CTS pilot training records and aviation publications materials, customer reports, and FileFlo product as of May 2026.
| Feature | FileFlo$299/mo · unlimited pilots + aircraft | ATP CTS~$100-$500/user/yr · per-pilot tiered |
|---|---|---|
| Pilot training records database (event dates by crewmember) | Not in scope — holds the signed compliance records, not the LMS-style training-event database | Core competency — pilot training records platform for Part 135 + Part 91 |
| Aviation maintenance publications library (OEM manuals + ICAs) | Not in scope — relies on ATP CTS-supplied OEM manual revisions as upstream | OEM manual + ICA distribution for §43.13 performance compliance source |
| Compliance document evidence platform (AI-classified binder) | 600+ doc types AI-classified per crewmember + aircraft + tail | Training-records + tech-pub access — not signed-record document evidence storage |
| 14 CFR §135.21 General Operations Manual (GOM/MOM) version control + POI binder | Holds + version-tracks §135.21 GOM/MOM revisions + FAA-acknowledgment correspondence | Does not hold §135.21 GOM/MOM document or revision history |
| 14 CFR §135.293 competency check signed evidence + check airman signature | Holds signed §135.293 IPC forms reconciled to the §135.63 crewmember file | Tracks completion date — does not hold the signed §135.293 form itself |
| 14 CFR §135.351 recurrent training completion certificate + training captain signature | Holds signed §135.351 certificates with ground-training subject coverage list | Tracks completion date — does not hold the signed §135.351 certificate itself |
| 14 CFR §135.345 PIC/SIC proficiency check signed write-up | Holds signed §135.345 PIC + SIC proficiency check evidence | Tracks completion date — does not hold the signed §135.345 write-up itself |
| 14 CFR Part 61 §61.56 flight review + §61.57 currency cross-reference to §135.293 | Holds §61.56 endorsement + §61.57 logbook currency evidence cross-referenced to §135.293 | Records training events — does not hold the Part 61 endorsement evidence |
| 14 CFR §135.63 crewmember recordkeeping binder | §135.63 binder organized per crewmember + aircraft + Part 61 cross-link | Database of dates — not a signed §135.63 recordkeeping file |
| 14 CFR §43.9 maintenance entries from contract Part 145 station | Holds signed §43.9 entries citing ATP CTS-supplied OEM manual revision | Supplies the manual rev — does not hold the signed §43.9 entry from Part 145 |
| Form 8130-3 Authorized Release Certificate attachments + Part 39 AD compliance evidence | Holds Form 8130-3 per component + Part 39 AD compliance binder | Not in scope — training-records + tech-pub library only |
| FAA POI / PMI surveillance binder (8900.1 Vol 3 Ch 18 / Vol 6) one-click PDF | POI/PMI-ready binder organized by CFR section + crewmember + aircraft | Operator must export + assemble compliance binder manually |
| Multi-regulation coverage (FAA + DOT + OSHA + EPA for hangar / ground ops) | 14 CFR + 49 CFR + 29 CFR + 40 CFR all in one platform | Aviation training-records + tech-pub only — single-domain scope |
| Pricing model | $299/mo flat, unlimited pilots + aircraft + users | Per-user / per-pilot subscription (~$100-$500/user/yr operator reports) |
| Free trial (no sales call) | 5-day full access, no card | Demo + per-pilot quote + user provisioning + onboarding process |
| Use case fit | Part 135 / Part 91 POI / PMI compliance evidence binder for surveillance | Part 135 / Part 91 pilot training records + OEM tech-pub library for chief pilots + mechanics |
ATP CTS prices on a per-user / per-pilot subscription model that varies by pilot count, aircraft type count, user count, and integration tier. Range cited from public sources and operator reports — verify directly with ATP CTS for an exact quote.
Where Each Tool Sits Inside 14 CFR §135.21, §135.293, §135.351, Part 61, and §43.9
The Part 135 + Part 91 recordkeeping regulations map cleanly onto the right operating model. Here is who does what.
14 CFR §135.21 — General Operations Manual (GOM/MOM)
§135.21 requires every Part 135 certificate holder (other than the §135.21(b) limited exceptions) to prepare, keep current, and follow a General Operations Manual (GOM) and Maintenance Manual (MM) acceptable to the FAA. The GOM/MOM must contain the §135.293 competency check procedures, the §135.351 recurrent training procedures, the §135.345 PIC/SIC proficiency check procedures, the §135.63 recordkeeping procedures, the §135.65 reporting mechanical irregularities procedures, the §135.67 reporting potentially hazardous meteorological conditions procedures, the §135.83 operating information for the pilot in command procedures, and the contract maintenance arrangement procedures under §135.411 and §135.443. The GOM/MOM must be revised whenever any procedure changes, must be made available to all operations personnel, and must be made available to the FAA POI on request. FAA Order 8900.1 Volume 3 Chapter 18 governs POI surveillance of Part 135 GOM/MOM. ATP CTS holds the pilot training records — it does not hold the §135.21 GOM/MOM document itself, it does not version-track GOM/MOM revisions, and it does not hold the FAA-acknowledgment correspondence chain. FileFlo wins here cleanly for §135.21: holds the GOM/MOM file with full version history, AI-classifies every revision against the referenced cross-procedures, links FAA acknowledgments to the revision chain, and produces the §135.21 POI-surveillance-ready binder in one click.
14 CFR §135.293 — Initial and Recurrent Pilot Testing
§135.293 requires every Part 135 pilot to pass a competency check (oral examination of pilot qualifications under §135.293(a), an instrument proficiency check under §135.293(b), and a flight check) in each aircraft the pilot is qualified to fly, within the preceding 12 calendar months, administered by a check airman approved under §135.337 or by the Administrator. The §135.293 oral examination covers the applicable aircraft systems, performance, operating procedures, emergency procedures, and the regulatory cross-references; the §135.293 IPC covers approach procedures (precision + non-precision), missed approach procedures, holding patterns, and emergency procedures under simulated IFR. The signed §135.293 IPC form is the document evidence the POI pulls during Part 135 surveillance. ATP CTS tracks the date the pilot completed the §135.293 IPC — that is the records- database surface. ATP CTS does NOT hold the signed §135.293 form, the check airman signature, the IPC write-up, or the §135.63 crewmember file linking the §135.293 event to the pilot's qualification record. FileFlo wins here for §135.293 evidence: holds the signed §135.293 IPC forms reconciled to the §135.63 crewmember file, AI-links every §135.293 IPC to the §135.351 recurrent training event and the §61.56 flight review endorsement, and produces the one-click §135.293 POI binder.
14 CFR §135.351 — Recurrent Training
§135.351 requires every Part 135 pilot to complete recurrent ground and flight training within the preceding 24 calendar months (12 calendar months for emergency procedures) covering the §135.345 PIC/SIC competency areas, the aircraft systems training, the operating procedures training, the emergency procedures training, the FAA-required ground-training subjects per §135.345 (meteorology, regulations, ATC procedures, weight-and-balance, fuel-planning, performance, NOTAMs, and the §135.293 IPC subject areas), and (for multi-engine aircraft) the emergency-procedure simulation requirements. The signed §135.351 recurrent training completion certificate with the ground- training subjects covered and the training captain signature is the document evidence the POI pulls during Part 135 surveillance. ATP CTS tracks the date the §135.351 recurrent was completed — that is the records-database surface. ATP CTS does NOT hold the signed §135.351 certificate, the ground-training subjects covered list, the training captain signature, or the §135.63 crewmember file linking §135.351 to the pilot's qualification record. FileFlo wins here for §135.351 evidence: holds the signed §135.351 certificates with ground- training subjects covered list, AI-classifies every §135.351 event to the §135.345 competency area, and produces the one-click §135.351 POI binder.
14 CFR Part 61 — Pilot Certification (§61.56 Flight Review + §61.57 Currency)
Part 61 separately requires every pilot acting as PIC to complete a flight review under §61.56 within the preceding 24 calendar months (1 hour of ground training + 1 hour of flight training with a certificated flight instructor, endorsed in the pilot's logbook), and §61.57 requires recent flight experience — 3 takeoffs and landings within the preceding 90 days for currency (in the same category, class, and type if a type rating is required), 3 takeoffs and landings to a full stop during the period beginning 1 hour after sunset and ending 1 hour before sunrise for night currency, and the §61.57(c) IFR currency requirements (6 instrument approaches, holding procedures, intercepting and tracking courses within the preceding 6 calendar months). The §61.56 + §61.57 endorsements and logbook evidence are required to pair with the §135.293 IPC — the §61.56 flight review covers the PIC currency baseline that the §135.293 IPC supplements with the Part 135 type-specific competency check. ATP CTS records the Part 61 event dates — it does NOT hold the §61.56 endorsement, the §61.57 logbook entries, or the cross-reference linking §61.56 / §61.57 to the §135.293 IPC in the §135.63 crewmember file. FileFlo wins here for Part 61 evidence: holds the §61.56 endorsement attachments, the §61.57 logbook currency evidence, and the cross-reference linking Part 61 currency to the §135.293 IPC and the §135.63 crewmember binder.
14 CFR §43.9 — Maintenance Records (Contract Part 145 Side)
§43.9 requires every person performing maintenance, preventive maintenance, or alteration on an aircraft, airframe, engine, propeller, or component to make an entry in the maintenance record of the work performed — including a description of the work, the date the work was completed, the name of the person performing the work, and (if the work was performed satisfactorily) the signature, certificate number, and kind of certificate held by the person approving the work for return to service (§43.7 RTS sign-off). The §43.9 entry must reference the methods, techniques, and practices acceptable to the Administrator — typically the current-revision OEM maintenance manual ATP CTS supplies in its maintenance publications library. ATP CTS is the upstream tech-pub source — the current-revision OEM manual the contract Part 145 station references is the §43.13 acceptable-data source. ATP CTS does NOT hold the signed §43.9 entry, the §43.7 RTS sign-off, the inspector signature, the §91.417 / §135.63 retention file, or the Form 8130-3 Authorized Release Certificate for installed components. The signed records are the document evidence the PMI pulls during Part 145 surveillance (and the POI pulls during Part 135 surveillance for the contract maintenance arrangement under §135.411 + §135.443). FileFlo wins here for §43.9 evidence: holds the signed §43.9 entries citing the ATP CTS-supplied manual revision, holds the §43.7 RTS sign-off and inspector signature, and produces the one-click §43.9 binder reconciled to the §135.63 recordkeeping file (or §91.417 retention file for Part 91 corp flight dept use). Civil-penalty exposure under 49 U.S.C. § 46301 runs up to $37,377 per violation per day for 2026 — a Part 135 surveillance event with §135.21 + §135.293 + §135.351 + §135.63 + §43.9 finding compound can escalate to a six-figure civil penalty exposure for the certificate holder.
Real Pricing Comparison
FileFlo is one flat price for the compliance document evidence layer regardless of pilot count or aircraft type scope. ATP CTS prices on a per-user / per-pilot subscription model tiered by pilot count, aircraft type count, user count, and integration scope. The math escalates with every additional pilot + every additional user.
* Pricing range based on public sources and operator reports across ATP CTS per-pilot tiers. ATP CTS does not publish all pricing — contact ATP CTS for an exact quote based on pilot count, aircraft type count, user count, and integration tier.
The pricing comparison is not apples-to-apples. ATP CTS is a pilot training records + maintenance publications platform; FileFlo is a compliance document evidence platform. The right operating model is “ATP CTS for the pilot training records database + FileFlo for the §135.21 / §135.293 / §135.351 / §135.63 / §43.9 audit binder” — combined cost typically lower than enterprise aviation compliance platforms alone.
When to Use Each (and When to Use Both)
Add FileFlo if you...
- Are a Part 135 operator whose POI surveillance pulls §135.21 GOM/MOM revisions and FAA-ack correspondence
- Need the signed §135.293 IPC + §135.351 recurrent + §135.345 PIC/SIC proficiency check evidence — not just ATP CTS dates
- Need the §61.56 flight review endorsement + §61.57 logbook currency cross-referenced to §135.293
- Need the §135.63 crewmember recordkeeping binder organized per pilot + per aircraft
- Need the §43.9 maintenance entries + §43.7 RTS sign-offs from the contract Part 145 station
- Are a Part 91 corp flight department needing §91.7 / §91.417 / §91.403 / Part 39 binder
- Want AI to auto-classify 600+ aviation compliance documents — no manual filing
- Need cross-regulation coverage — FAA + DOT + OSHA + EPA for hangar / ground ops
- Need a one-click FAA-ready audit binder for POI / PMI surveillance events
- Want unlimited pilots + aircraft without per-pilot subscription inflation
Keep ATP CTS if you...
- Need the pilot training records database tracking event dates by crewmember
- Need LMS integration for §135.351 ground-training delivery
- Need chief pilot weekly currency check before assigning next 135 leg
- Need multi-aircraft-type training-records access across Cessna / Gulfstream / Bombardier / Embraer fleets
- Need OEM maintenance publications library for §43.13 acceptable-data source
- Need multi-base Part 135 operator user access control with training-captain workflows
- Need training-delivery + records-tracking single-vendor consolidation
"We Added FileFlo to ATP CTS Because..."
Real workflows Part 135 chief pilots and Part 91 corporate flight department directors of operations describe after pairing FileFlo with ATP CTS.
"I'm chief pilot at a Part 135 charter with 14 pilots flying two Cessna Citation types. ATP CTS tracks every pilot's §135.293 IPC date, §135.351 recurrent training date, and §61.56 flight review date — the database is real, the LMS integration works, and we are not switching off it. When the FAA POI showed up for surveillance under 8900.1 Volume 3 Chapter 18, the first request was our §135.21 GOM/MOM revision history with FAA-ack correspondence going back five years, and the second request was signed §135.293 IPC forms with check airman signatures for every pilot, plus §135.351 recurrent certificates with the ground-training subjects covered list, reconciled to the §135.63 crewmember file. ATP CTS shows the dates — but it does not hold the signed §135.293 form, the §135.351 certificate, or the §135.63 file. We added FileFlo at $299/mo for the compliance evidence binder. POI surveillance now closes in 2 hours instead of three days, and our last surveillance had zero §135.21 or §135.293 findings."
"We're a mid-size Part 135 operator running ATP CTS for 28 pilots across four aircraft types — Gulfstream, Bombardier, Embraer, and Cessna. ATP CTS costs us about $9K a year for the per-pilot subscription and it is the right tool for crew-currency tracking; we are not switching off it. But our last POI surveillance pulled signed §135.293 IPC forms with check airman signatures, signed §135.351 recurrent certificates, §61.56 flight review endorsements cross-referenced to the §135.293 IPC, and §135.63 crewmember files organized per pilot per aircraft. ATP CTS supplies the training dates — but it does not hold the signed forms, the endorsements, or the §135.63 file. We added FileFlo for the compliance document evidence layer. Combined ATP CTS + FileFlo annual spend is still less than the enterprise aviation compliance platforms quoted us, and we kept the crew-records workflow that runs daily chief pilot operations."
"I'm DO at a Part 91 corporate flight department with three tails — a Gulfstream G650, a Bombardier Global 7500, and a Cessna Citation Latitude. We use ATP CTS for the pilot training records database and the OEM maintenance publications library our contract Part 145 station references when performing maintenance under §43.13. ATP CTS is the right tool for crew-records and tech-pub access. But the §91.7 airworthiness determination before each flight and the §91.417 retention file across all three tails — including the contract Part 145 station §43.9 entries, the §43.7 RTS sign-offs, the §91.403 maintenance accountability records, and the AD compliance evidence under Part 39, plus the Part 61 §61.56 + §61.57 currency endorsements for our two contract pilots — is not what ATP CTS holds. We added FileFlo for the §91.7 / §91.417 / §91.403 / Part 39 + Part 61 currency binder per tail. The insurance underwriter due-diligence request that used to take two weeks now takes under an hour, and our last underwriter renewal closed without a single open §91.7 documentation request."
Frequently Asked Questions
What is ATP CTS, and who is it built for in 2026?
ATP CTS (Aircraft Technical Publishers — Compliance Training Solutions, sometimes branded "ATP CTS" within the broader ATP / Aviation Training Service product family) is an aviation crew training records and maintenance publications platform built specifically for Part 135 on-demand air carriers and Part 91 corporate flight departments that need to track pilot training records under 14 CFR Part 61, §135.293 competency / proficiency checks, §135.351 recurrent ground and flight training, §135.345 pilot tests for proficiency, plus maintenance manuals + Instructions for Continued Airworthiness (ICAs) the Part 145 contract repair station references under §43.13. The ATP CTS product line historically focuses on the pilot training records pain point — the chief pilot or director of operations who needs to prove every Part 135 pilot completed the §135.293 competency check within the preceding 12 calendar months, the §135.351 recurrent training within the preceding 24 calendar months, the §135.345 PIC/SIC proficiency check, plus the Part 61 §61.56 flight review and §61.57 currency requirements — and pairs that with an aviation maintenance publications library mechanics search for current-revision OEM manuals. ATP CTS competes against aviation training record platforms like CTS Aviation, Veryon (training-records side, post-2024 merger with ATP), CAMP Systems training-records modules, and OEM-direct training portals. ATP CTS is the pilot training records + maintenance manual library; FileFlo is the compliance document evidence layer that holds the §135.21 General Operations Manual file, the §135.293 + §135.351 + §135.345 signed training records binder, the §43.9 maintenance entries + §43.7 RTS sign-offs, and produces the one-click FAA Principal Operations Inspector (POI) / Principal Maintenance Inspector (PMI) surveillance binder organized to FAA Order 8900.1 Volume 3 (Part 135) and Volume 6 (Part 145) inspector checklists.
How much does ATP CTS cost vs FileFlo?
ATP CTS prices on a per-user / per-pilot subscription model tailored to Part 135 + Part 91 crew training records scope — number of pilots in the training-records database, number of aircraft types in the maintenance publications library, number of users with crew-records access (chief pilot, DO, training captains, chief inspector), and the integration tier (basic records access vs full LMS / training-delivery integration). Public pricing varies; ATP CTS sells through a sales-led process. Industry reporting and Part 135 operator disclosures suggest ATP CTS subscriptions run roughly $100-$500 per user per year for the pilot training records and maintenance publications access layer — a small Part 135 charter with 4-6 pilots and a single aircraft type at the lower end, scaling to a multi-base Part 135 operation with 25-40 pilots and 3-5 aircraft types running multi-thousand-dollar annual contracts on the upper end. FileFlo is a flat $299 per month or $2,990 per year — unlimited pilots, unlimited aircraft types, unlimited users, all compliance features. The pricing comparison is NOT a substitution comparison. ATP CTS sells pilot training records + maintenance publications access; FileFlo sells the compliance document evidence binder the FAA POI/PMI pulls during surveillance. The right operating model for most Part 135 + Part 91 operators is keep ATP CTS for the pilot training records database the chief pilot accesses every week AND add FileFlo for the §135.21 GOM file, the signed §135.293 + §135.351 + §135.345 training records binder, the §43.9 + §43.7 maintenance evidence, and the Part 61 currency cross-reference. Verify ATP CTS pricing directly during the ATP CTS sales process; FileFlo pricing is locked at getfileflo.com/pricing.
Does FileFlo replace the pilot training records database ATP CTS provides?
No — and the Part 135 + Part 91 pairing is exactly the use case where this distinction matters most. ATP CTS is the pilot training records platform where the chief pilot tracks every Part 135 pilot's §135.293 competency check date, §135.351 recurrent ground / flight training completion, §135.345 PIC/SIC proficiency check, Part 61 §61.56 flight review date, §61.57 currency (90-day, night, IFR), and the maintenance publications library the contract Part 145 station references for §43.13 performance compliance. That crew-records workflow is the daily chief pilot + DO surface — it runs every week as pilots fly, it integrates with the training-delivery LMS, and it is the single pane of glass the chief pilot uses to verify a pilot is current before assigning the next 135 leg. FileFlo does NOT attempt to replace that workflow. FileFlo is the destination for the completed compliance documents — the §135.21 General Operations Manual file with FAA-acknowledgment correspondence, the signed §135.293 competency check forms with check airman signatures, the §135.351 recurrent training completion certificates, the §135.345 PIC/SIC proficiency check records, the §135.63 recordkeeping binder organized per crewmember + per aircraft, the Part 61 §61.56 + §61.57 currency evidence cross-referenced to the §135.293 file, plus the §43.9 maintenance entries + §43.7 RTS sign-offs the contract Part 145 station files against the ATP CTS-supplied OEM manual revision. The combined operating model is: ATP CTS for the pilot training records database the chief pilot accesses every week + FileFlo for the §135.21 / §135.293 / §135.351 / §135.345 / §43.9 compliance document evidence binder the POI/PMI pulls during surveillance.
Can FileFlo hold the 14 CFR §135.21 General Operations Manual file the POI pulls during Part 135 surveillance?
Yes — and this is FileFlo's strongest use case for ATP CTS-running Part 135 air carriers. 14 CFR §135.21 requires every Part 135 certificate holder (other than those operating under §135.21(b) limited exceptions) to prepare, keep current, and follow a General Operations Manual (GOM) and Maintenance Manual (MM, often combined as the GOM/MOM or GMM in Part 135 operator terminology) acceptable to the FAA Administrator. The GOM/MOM must contain the procedures, instructions, and information necessary to operate the Part 135 certificate — the §135.293 competency check procedures, the §135.351 recurrent training procedures, the §135.345 PIC/SIC proficiency check procedures, the §135.63 recordkeeping procedures, the §135.65 reporting mechanical irregularities procedures, the §135.67 reporting potentially hazardous meteorological conditions procedures, the §135.83 operating information for the pilot in command procedures, and the contract maintenance arrangement procedures under §135.411 and §135.443. The GOM/MOM must be revised whenever any procedure changes, must be made available to all operations personnel, and must be made available to the FAA POI on request. FAA Order 8900.1 Volume 3 Chapter 18 governs POI surveillance of Part 135 GOM/MOM compliance plus OpSpecs review. ATP CTS holds the pilot training records and the maintenance publications library — it does not hold the §135.21 GOM/MOM document itself, it does not version-track GOM/MOM revisions, and it does not hold the FAA-acknowledgment correspondence chain. The Part 135 operator that walks into POI surveillance with ATP CTS-supplied pilot training records but cannot produce the current-revision §135.21 GOM/MOM with version history, revision dates, and FAA-acknowledged revision letters is the operator that picks up a §135.21 finding (and in repeat-finding cases the §135.25 certificate enforcement action). FileFlo holds the §135.21 GOM/MOM file, version-tracks every revision, holds the FAA-acknowledgment correspondence, and produces the FAA-ready §135.21 binder in one click — with the cross-references to §135.293 competency check procedures, §135.351 recurrent training procedures, and §135.63 recordkeeping procedures readable to the POI.
Does FileFlo hold the signed §135.293 + §135.351 + §135.345 training records evidence + Part 61 currency cross-reference the POI pulls during a Part 135 surveillance event?
Yes — and this is where the ATP CTS + FileFlo pairing closes the most operational risk. 14 CFR §135.293 requires every Part 135 pilot to pass a competency check (oral exam, instrument proficiency check, and flight check) in each aircraft the pilot is qualified to fly, within the preceding 12 calendar months, administered by a check airman approved under §135.337 or by the Administrator. 14 CFR §135.351 requires every Part 135 pilot to complete recurrent ground and flight training within the preceding 24 calendar months (12 months for emergency procedures) covering the §135.345 PIC/SIC competency areas, the aircraft systems, the operating procedures, the emergency procedures, and the FAA-required ground-training subjects per §135.345. 14 CFR §135.345 separately requires the PIC and SIC to pass proficiency checks demonstrating the operating skills under simulated IFR or actual IFR conditions when the certificate authorizes IFR operations. 14 CFR Part 61 §61.56 separately requires every pilot acting as PIC to complete a flight review within the preceding 24 calendar months, and §61.57 requires recent flight experience (3 takeoffs and landings within the preceding 90 days for currency, plus night and IFR currency requirements). ATP CTS tracks the date the pilot completed each event — that is the records-database surface. ATP CTS does NOT hold the signed evidence: the §135.293 competency check completion form with the check airman signature, the §135.351 recurrent training completion certificate with the ground-training subjects covered and the training captain signature, the §135.345 PIC/SIC proficiency check write-up, the §61.56 flight review endorsement, the §61.57 logbook currency evidence cross-referenced to the §135.293 IPC, or the §135.63 crewmember recordkeeping file showing how the §135.293 / §135.351 / §135.345 / Part 61 events fit together for each crewmember. The signed records are the document evidence the POI pulls during Part 135 surveillance. The Part 135 operator that has the ATP CTS-supplied training dates but cannot produce the signed §135.293 + §135.351 + §135.345 + §61.56 + §61.57 evidence reconciled to the §135.63 crewmember file is the operator that picks up a §135.63 finding (and in repeat-finding cases the §135.293 / §135.351 enforcement action). FileFlo holds the §135.63 crewmember binder, the signed §135.293 + §135.351 + §135.345 forms, the §61.56 + §61.57 cross-reference, and produces the one-click POI surveillance binder organized to the FAA Order 8900.1 Volume 3 Chapter 18 inspector checklist.
What about the maintenance side — does FileFlo hold §43.9 entries the contract Part 145 station files against ATP CTS-supplied OEM manual revisions?
Yes. The Part 135 + Part 91 operator running ATP CTS for crew training records and the maintenance publications library typically contracts maintenance to a Part 145 repair station that performs the work under the §43.13 acceptable-data source — the current-revision OEM maintenance manual ATP CTS supplies. ATP CTS is the upstream tech-pub source for §43.13 performance compliance. ATP CTS does NOT hold the signed evidence the contract Part 145 station files when the work completes: the §43.9 maintenance entry citing the ATP CTS-supplied manual revision and date, the §43.7 RTS sign-off, the inspector signature, the §91.417 retention file (for Part 91 corp flight dept use) or the §135.63 recordkeeping file (for Part 135 use), the Form 8130-3 Authorized Release Certificate for installed components, and the Airworthiness Directive compliance evidence under Part 39 / §91.403. FileFlo holds the §43.9 + §43.7 + §91.417 / §135.63 + Form 8130-3 + Part 39 binder per aircraft tail, AI-classified, retention-tracked, and produced as the one-click POI/PMI surveillance binder. Civil-penalty exposure under 49 U.S.C. §46301 runs up to $37,377 per violation per day for 2026 — a Part 135 surveillance event with §135.21 + §135.293 + §135.351 + §135.63 + §43.9 finding compound can escalate to a six-figure civil penalty exposure for the certificate holder.
Authored by Chad Griffith, Founder of FileFlo. Last reviewed 2026-05-31. Software perspective — comparing ATP CTS (aviation pilot training records + maintenance publications) and FileFlo as compliance software products. References: 14 CFR §135.21, 14 CFR §135.293, 14 CFR §135.351, 14 CFR Part 61, 14 CFR §43.9, 49 U.S.C. § 46301.
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