Originally Posted by
dera
Why is the 3 hours for your private not compliant with 61.65(c)?
It could be, but it might not count towards the 15 hours of 61.65(d)(2). A CFI-A can do the PPL instrument training, even without a CFI-I.
Those three hours could also count towards 61.65(d)(2) only if the instructor is also CFI-I. If that's the intent, and you're really going to need those three hours, ask the CFII to log it in such a manner that a DPE knows it's good for the IR when he reviews your book.
I think it's OK towards the 40 hours, but IMO it's sketchy to try to apply the PPL time to the 15 CFII hours. It is a different purpose... the PPL training is about survival, the IR training is about precise procedures and PTS standards.