Or, to put it another way: The BIFM is an integral part of the IR(A) and so if the ATO holds approval for the IR(A) it can clearly issue a CCC for the BIFM. However, as Whopity rightly points out, all training for the IR(A), including the BIFM, must be completed either by an IRI or by an FI qualified in accordance with FCL.905.FI(g). Since an IRI cannot deliver training for the CPL(A), this training must have been conducted by an FI and, to issue a CCC for the BIFM, that FI must also have been qualified to deliver training for the IR(A). The instrument training that is included in a CPL(A) course conducted by an FI not qualified in accordance with FCL.905.FI(g) provides credit for the BIFM only if and when the licence is subsequently issued.