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Actually now that I read it a few more times, I believe those 20 hours do have to be dual. However the 10 hours for the 300nm cross country and the 5 for night vfr can be solo. In which case the cost of the extra checkride for a private multi add on first puts it almost equal to just paying...

I am looking for clarification on how much of the time requirements listed in 61.129 for initial multi engine commercial rating must be with an instructor? Specifically the 20 hours of 61.129, b, (3)? At first I thought of those 20 hours, only the 3 in (v) need to be with instructor in...