What if Unusual Attitude completed the CPL and FI before the expiry of his ATPL theory credits, then if 3 years lapsed after exam passes, to gain the IR retook JUST the IR exams which I believe are now available in isolation? Would he be able to gain Frozen ATPL?
A similar problem is faced by those that may become CPL holders and have no means to upgrade to ATPL without starting from scratch with the exams.
Presumably the CPL or ATPL theory credits have to be valid (ie passed less than 3 years ago) to commence FI course? So what if a Frozen ATPL holder has been flying for 5 years and then decides to become FI - must they then resit CPL or ATPL theory?