Yeah. Our local FSDO made that mistake too. They were going to violate the guy who did the annual. The feds have "guidance" that they are actually bound by:
Charlie Longley, over on Super Cub, found it for me:
If registration and airworthiness certificates are not available, the aircraft does not need to be reported in unairworthy condition; however, the owner or operator should be informed that the documents required by 14 CFR part 91, § 91.203(a)(2), should be in the aircraft and the airworthiness certificate displayed when the aircraft is operated.
https://www.faa.gov/sites/faa.gov/files/training_testing/testing/ia_info_guide.pdf
Here is the guidance for getting an Airworthiness Certificate for a Canadian aircraft. Note that some say that if the Canadian aircraft had been "converted" to "owner maintenance," then it becomes hopeless. But otherwise, here:
Order 8130.2J - guidance that is mandatory for FAA inspectors:
2.2 – an ASI is authorized to issue an Airworthiness Certificate.
2.3 – outlines the procedure:
Complete form 8130-6 (owner does this)
Review TCDS
Review records – current registration, maintenance.
Inspect – markings, data plate – both present and conform.
Look for violations of 14 cfr 45.13(c) or (e) – these are the big deal data plate regulations – this aircraft has its original 1940 data plate.
Verify – Type Certificate conformance, ADs, Repairs, Alterations. (part of the Annual Inspection).
Verify – placards (be sure to have limitations posted somewhere – CAA form 308?)
Document – FAA fills out 8100.1.
Allow the owner to correct stuff (like the inspection within 30 days?) I believe this one permits the ASI to simply inspect the entry for Annual Inspection (equivalent to a 100 hr inspection).
Issue! Form 8130-6 and the certificate.
FAA makes a record entry in the logbook.
Done!
Chapter 3 (3.6(a)) – requires a 100 hour inspection within (prior to) 30 days of the conformance inspection.