Billiebob is incorrect. There are already approved ATOs that are compliant. While the RTF side of approval was a side line we made it compliant at the same time as doing the FTO and TRTO and now everything is covered under a single ATO approval.
I also know of two flying schools that were just RTF that I have helped produce manuals and procedures for in order to become compliant.
Not everyone has buried there heads in the sand.