Originally Posted by
jedinein
Not quite. The FAA's National Legal Council closed that loophole through a letter of interpretation several years ago. Outside of part 141, any training for the purpose of the CFI initial must be from an experienced (two year) flight instructor. I'll post the link once I find it.
I doubt they could enforce that the way the regs are written. Flight training is only FAR flight training when it is used for aeronautical experience requirements. Extra training above the minimum required can be done by anyone, even a non-CFI.
But if they issued a letter, probably best to play it safe.