On Wednesday, December 4, 2019 at 2:46:39 PM UTC-7, wrote:
On Wednesday, December 4, 2019 at 4:28:18 PM UTC-5, wrote:

My question is about doing a FIRC early, not late. Many months before the expiration date.

There are circumstance that allow this, but only up to about 3 months prior to expiration. Advisory Circular 61-65H discusses this in section 30.2.