CFR Part 61.57 Paragraph (d) pg 63 FAR/AIM 2015
Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency ONLY by completing an instrument proficiency check.
What it means in plain English: Assuming that you were current during the first 6 months but then did nothing to retain your instrument experience requirement during the second 6 month period you would have failed to meet the Instrument Currency requirements 'for more than six calendar months'. So, yes the second 6 month period is STILL a grace period during which time you could utilize the Safety Pilot Concept. Beyond that, you would require an IPC in order to regain instrument currency.
CFR Part 61.56 Paragraph (a) pg 60 FAR/AIM 2015
Flight Review. (a) Except as provided in paragraphs (b) and (f) of this section, a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. (c) Except as provided in paragraphs (d), (e) and (g) of this section, no person may act as pilot in command of an aircraft unless, since the beginning of the 24th calendar month before the month in which that pilot acts as pilot in command, that person has (1) Accomplished a flight review in an aircraft for which that pilot is rated given by an authorized instructor (2) A logbook endorsed from an authorized instructor who gave the review certifying that the person has satisfactorily completed the review.
This includes all 61.75 Restricted License holders. You are required to have a flight review with a current and authorised FAA Flight Instructor prior to exercising the privileges of your FAA Restricted license, initially after receipt of it and every 24 calendar months thereafter. Non-FAA Flight instructors are are not allowed to conduct this review. This is regardless of the flight review requirement of your Non-FAA license by a Non-FAA Flight Instructor. It was clearly stated on your original Foreign License Verification Letter.
CFR Part 61.1 Paragraph (b) pg 36 FAR/AIM 2015
Authorized instructor (ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with 61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate.
CFR Part 61.75 Paragraph (a) pg 76 FAR/AIM 2015
Private pilot certificate issued on the basis of a foreign pilot license. Sometimes referred to as a restricted, piggyback or validation license. Holders of this certificate are required by FAA and International regulations to accomplish a flight review given by an FAA flight instructor under CFR part 61.56 initially and every 24 calendar months thereafter. Remember, this requirement is stated in plain English on the Foreign License Verification Letter you presented to the examiner or inspector in order to have the license issued in the first place. Without it you may never exercise the privileges of the FAA license. Also, a license issued under CFR 61.75 will NEVER give you more privileges than a pilot who has a standalone FAA license. By the way, according to CFR 61.75 paragraph (b) (3) pg 76, this certificate cannot be issued if you hold and standalone U.S. pilot certificate other than a student pilot certificate.
CFR Part 61.113 Paragraph (a) pg 98 FAR/AIM 2015
FAA Private pilot certificate issued under any regulation Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft (US Registered). This is regardless of non US licenses the pilot holds, the country the flight is conducted in or whether itís for aerial displays etc..
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