Since the FSA deadline is coming up in less than two years, I feel that we have the right to apply and submit a DMAC at this point. The disadvantage of this is that if we don’t give a deadline (pass the final exam by spring 2022), then we don’t just have to retake the PA and find out if all the recent ASA changes affect us, but also may have to retake the DMAC. If we don’t meet the deadline, then we will have to pass the final exam by spring 2022.
Because of this, I believe the most optimal sequence of events would be to pass all FSA exams by spring 2022, get pass results by July 2022, start DMAC and submit by August (if you are). make sure you don’t need to take the exam more than once) based on the FAC #139 timeline, and then attend the FAC in December, just in time to pass the January 1, 2023 deadline. you can start with cuphead before you get your pass in July 2022 (this will allow you more time to complete it), especially if you are sure you did well on the test investigation; alternatively, you can start DMAC at any time, just in case you need it more than once.