Can a F-1 student take advantage of CPT without registering for a course credit?

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I am trying to find out if it is possible to take advantage of curricular practical training (CPT) without having to register (and pay) for a course credit. DSO says that one must be a full-time registered student for CPT to be approved, but I think it is a school policy and not the law. Does any one have any experience?

Here is the relevant section from 8 CFR 214.2(f):

(i) Curricular practical training programs. An F-1 student may be authorized by the DSO to participate in a curricular practical training program that is an integral part of an established curriculum. Curricular practical training is defined to be alternative work/study, internship, cooperative education, or any other type of required internship or practicum that is offered by sponsoring employers through cooperative agreements with the school. Students who have received one year or more of full time curricular practical training are ineligible for post-completion academic training. Exceptions to the one academic year requirement are provided for students enrolled in graduate studies that require immediate participation in curricular practical training. A request for authorization for curricular practical training must be made to the DSO. A student may begin curricular practical training only after receiving his or her Form I-20 with the DSO endorsement.​

The CPT in question will be for the summer for a Ph.D. student that has completed all requirements except dissertation. CPT will be directly related to the dissertation.
 
I've always heard that you need to be registered for a course to use CPT, and that you need to be registered for that course at the same time the CPT is going to be used. With that said, I know someone who was able to use CPT (after a lot of visits and arguments with the DSO, so it's not easy), without being registered for a course. BUT she had to be registered for the course the following semester. So basically she used her CPT the semester before registering for the course. I think the issue she had was that the fact that the internship was not a requirement for the degree, but an elective.

As I understand it, it's the DSO that approves CPT, so it mainly depends on how your DSO interprets or understands the law. But 99% of the time, you have to be registered for course credit at the same time you use your CPT.
 
Thanks folu for your response

I just want to make sure that even if the DSO can be convinced to approve CPT without regestering for a course there is no violation of status. From reading the law it does not appear that this will be the case.
 
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