Does a CFI need TSA approval to provide endorsement training to non-US citizens, such as the complex, high performance and tailwheel endorsements laid out in 14 CFR 61.31?
Recurrent training is exempt from TSA approval, however training for an endorsement isn't recurrent because it doesn't have to happen again. And it includes training in an aircraft, which usually requires TSA approval.
Some places such as AOPA suggest all of 61.31 is exempt:
He/she is seeking recurrent training, such as a flight review, instrument proficiency check, or flight training listed under 14 CFR 61.31
But the TSA only suggests that 61.31(g) is covered:
High Altitude Training (HAT) 14 CFR Part 61.31(g) - Type rating requirements, additional training, and authorization requirements.
If only 61.31(g) is exempt then only high altitude endorsement training is exempt, and TSA approval is required for complex, high performance and tailwheel. Is that accurate?
Government references are highly appreciated.