The two systems CASA currently have in place are CAR 31 and Part 66 for MPL. On June 26 2015 CAR 31 will cease to exist. Until that date you should be free to submit a CASA SOE directly to CASA for assessment under CAR 31. CASA will automatically issue you a Part 66 license endorsement (not a CAR 31 as nobody holds a CAR 31 license anymore). Prior to and following that date you can be assessed by an approved Part 147 training organisation who can issue a Form 465 to CASA to issue you an endorsement under Part 66. Under part 66 CASA take no place in the assessment process. They merely issue your new license. To answer your question CASA should accept your application without a 465 PRIOR to June 26, but it must be submitted under CAR 31 using an SOE book. After that date they won't. I hope that makes sense.