Hi Youngbuck, thanks for your involvement.
I do agree with you by principle, but strictly talking about requirements, I shall apply what is required by the regulation.
If my complex aircraft is not under AOC, my understanding is that SPO.SPEC.MCF is not required.
Different story is: should I have a procedure because MCF are sensitive?
So far, I shall not be required to comply with SPO.SPEC.MCF is not under AOC.