Expiring USCG License

See 46 CFR 10.205(a):
An MMC is valid for a term of 5 years from the date of issuance. Except upon the written request for the immediate issuance by the applicant, the Coast Guard will post-date the issuance of an MMC renewal that includes no other transactions up to 8 months from the date that the Coast Guard accepts a complete application as required in this part. If the expiration date of the mariner’s active credential is beyond 8 months of the date that the Coast Guard accepts a complete application as required in this part, the new credential issue date will be 8 months from the date of application acceptance at which time the currently active credential will become invalid in accordance with paragraph (d) of this section. Otherwise, the new credential issue validity date will coincide with the expiration date of the active credential held by the mariner. All other MMC transactions will be processed for immediate issuance.

That used to be true, but not since the MMC was created in 2009. See 46 CFR 10.227(b): “A credential may be renewed at any time during its validity and for 1 year after expiration.”

Can anyone, especially Mr Cavo, verify that this is still the regulation?
When I real the CFRs I dont read it that way.

My interpretation of 46CFR 11.201 would mean recency is now a requirement for an ‘applicant,’ I’m led this way by paragraph (a) where ‘applicant’ is described as anyone looking for original, ROG, renewal, or duplicate. From there when you read ©(2):

(2) An applicant for a national officer endorsement must have at least 3 months of required service on vessels of appropriate tonnage or horsepower within the 3 years immediately preceding the date of application.

which leads me to be believe the absence of a qualifier like “original” or “raise of grade” means its required for everything.

And while we are at this, if the regulation has changed do you need recency to get the open book renewal modules? Seeing as the NMC says they are administered in accordance with 10.227 which states that you must meet requirements from part 11… its like chasing your tail with this some days.

46 CFR 10.227 - Requirements for Renewal

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a note for you hanging on the beach for a while: consider putting your license in “suspended animation” with the NMC. Sorry, I can’t think of the name of the process or state but it basically stops your license from aging. You’ll prob have to do STCW but the important stuff ‘keeps’.

Continuity. 46 CFR 10.227(g).

Document of Continuity