Cap Bloggs
Well, yes, I agree, the instrument portion of a circling approach ends at the MDA, then it is a visual maneuver. Well, I'll have to do some research, as it was an USAF technicality that was more pedantic than real. The AF Instrument Manual also stated the FAF for an ILS was GP intercept, not the charted FAF that was used for timing on the LOC.
Let me see what I can find
GF