CAAP could not even conduct breifings to the industry on the new CARs, Why? because they themselves have problems with the way the CARs where written! Nobody at CAAP would dare teach those CARs to the industry! Even the guys sent by ICAO as consultant to CAAP would not dare teach or give the briefings to the industry because they will be flooded with questions they could not answer.
At the present state of the CAAP, and the way I see things happening at the agency, CAAP will fail the audit (unless, political intervention would happen). Because if they do pass, EU, ICAO and FAA will look very stupid if CAAP passed with flying colors!