Fuji yes it certainly is I guess if you talk to ten FAA inspectors you,ll get as many different answers.I,ve raised this one many times in the States at schools and with the FAA.Whenever I,ve rented I,ve never had to have a bienniel only a quick check ride but as I don,t fly Stateside anymore haven,t rented over there for about 3 years.I think most people are confused about the so called licence the FAA give them issued on the basis of their "earnt" licence its really a validation yet you hear lots of people talk about having an "American licence" but without their Uk one being valid they have nothing at all.Its one area where our licencing authorities are way ahead in how we treat visiting ICAO licence holders for day VFR priveleges.I promise the confusion on this one will run a run.