For example, in some legitimate dry rental agreements, the owner may perform maintenance or execution work to enhance safety, but this should not necessarily mean that the owner has retained operational control of the aircraft. The determination of the party exercising operational control is generally established on the basis of all the circumstances. But it also means that commercial or air transport pilots must also observe “their P`s and Q`s” when flying for hire as part of a wet or dry lease. According to the FAA, one of the most worrying trends they see is the use of computer and mobile applications to facilitate air traffic by connecting potential passengers to aircraft owners and volunteer pilots. Some of these applications provide both the aircraft and the crew to customers seeking air travel. Editor`s Note: For the latest developments on this subject, please read www.aopa.org/news-and-media/all-news/2020/march/pilot/for-the-record-who-is-in-control (February 2020) 135 non-self-demsis operations remain a problem for the flying public. Not only does it create security problems, but it also takes on the activities of legitimate operators. Anyone with questions about dry leases or cost-sharing fees should contact FAA regulations or ask for assistance from your fsDO on site. If you have any questions or would like to discuss a dry rental agreement, please contact Brennan Block (brennan.block@brownWinick.com) or by phone at (515) 242-2441. Following updates to Advisory Circular 91-37 in 2016, In April 2020, the FAA issued inspection guidelines in the Flight Standards Information Management System to assist safety inspectors in assessing compliance with Part 91 (including Part 91.23) requirements for leases and conditional sales contracts. In particular, the FAA focuses on the fact that, as part of a “leasing” scheme, the lessor/owner does not actually offer air transport for hire (without certification or compliance with the operational requirements of the FAR 119, 121, 125 or 135 parts) and that the taker does have operational control of the aircraft.