Point I'm trying to make is that a Floridian/Californian FAA instructor IS NOT authorised for this task
Unless dual rated. I will be doing an FAA BFR in a couple of months with an FAA CFII, who also holds JAA FI ratings. Therefore I can kill two birds with one stone....so to speak.
On the subject of complexity, it is bloody complex. I don't see why an LPC shouldn't start the clock ticking from anytime (other than the "three months prior"). After all an LPC is an LPC with authorised examiner.
If revalidating by experience, you have to wait until the last 3 months of the Rating validity period before an Examiner may sign the form, no matter when you achieved the 12 hours.
I got mine validated the day after the first 12 months was up....two times in a row....including 2005.