Hi Flying Tooth Driller,
We were able to get the TSA to change their implementation. Right now we have till the 19th of December before full registrations will go into effect for Flying activities that do not require a Visa.
So for now, Category 4:
Candidates who are current and qualified on the aircraft for which they are requesting training.
Will not go into effect until after the 19th of December.
BFRs, currency and checkouts have been removed from Category 3 and placed in Category 4. They also fall under the grace period listed above as long as the pilot holds an FAA Licence.
With Category 3:
Candidates who request training for aircraft with a maximum certificated takeoff weight of 12,500 pounds or less.
Will only apply to students starting a training course after the 19th of October. To give an example, lets say you came to the U.S. to do a Private and an Instrument Rating. You started your Private on the 10th of October, and then started the Instrument on the 10th of November. You would only have to apply though the TSA for the Instrument Portion since it is a new, course/rating. The Private would not require you registering since it commenced prior to the 20th of October.
For U.S. Citizens, the rule has been chanced to allow for a Flight Instructor to sign in the Pilot's Logbook that their citizenship has been established and that is enough to satisfy the rule.
Take Care,
Richard
P.S. Sorry I have not been on in several days. It has been extremely busy here the last week. As I hear more, I will post it.