*sigh*
OK.
1/. Reg or not reg has nothing to do with it - but for the record, RAAus reg is not "registered". The whole point of CAO101.55 is that it exempts you from certain provisions of the CARs, including Reg, Medical, Licences, Maintenance reqts.
2/. Yes you can use RAAus instructional hours for an FI(A) upgrade - as I recall you are able to count up to 250 hours of "other instruction" and it falls into that category.
As for the mass-debate I had here 9 months ago, I made my case to Screaming Skull along the lines I argued here. About 4 months later I finally got a response that said "no that's wrong, you CAN use RAAus solo time to satisfy the 100 (70?) hour Command time reqt for a 200 hour CPL" but their reasoning and explanation was along the lines of "because I said so".
...which is really good because now I can integrate my RAAus school and GA school and give people a 200 hour CPL solution that doesn't require masses of extra expenditure. I'm not as anti-RAAus as some would have you believe
