...Who was doing the audit, FAA personnel or UA? Presuming FAA, ..
Industry is self regulated . FAA audits paperwork years later and fines airline. Usually airline pays 10% of initial fine amount after 10 years. There are several examples in the past.
That's what I thought. The logical explanation for the two additional flights was a simple case of damage being done, wait for the plane to arrive back at a location where the inspection could be completed.
There are a number of misconceptions here.
First, as an airline, you NEVER fly an airplane with known airworthiness discrepancy, whether legal or physical. That turns an inadvertent and innocent violation into a willful one (much higher penalty), and calls your overall compliance disposition into question. You get the inspection done on the spot (which was most likely available to United), or get a ferry permit to where the inspection can be done. Likely a regular Airframe and Powerplant mechanic (A&P) performed and signed off the work, but it did not receive the second set of eyes by an Inspector Authorization mechanic (IA). As has been noted, this was likely caused by a breakdown in internal communications, after United was put on notice by FAA.
Second, the industry is not self regulated. Airlines strive to maintain the highest service standards and do self audit. But it is the FAA that regulates and imposes fines.
Third, FAA civil penalty cases take nowhere near 10 years to work their way through the system. There is some delay between when the FAA maintenance inspector finds the discrepancy, and when the civil penalty notice is issued. It has to be evaluated by legal, and in a high dollar case like this, approved by FAA senior leadership.
Fourth, usual settlement is not 10% of the proposed penalty. More likely 80% of the proposed penalty if you can show mitigating circumstances, or zero dollars if you have a great defense and can prove the FAA inspector was wrong. Also, if you discover the error through your own internal audit program and self-report before the FAA finds it, the proposed penalty is likely to be much less when and if the notice of civil penalty is issued.
In my opinion FAA penalty amounts have gotten out of hand, as airlines are indeed highly self-motivated to be compliant. High penalties, except for egregious and willful violations, does not serve much of a purpose other than to drive up the cost of doing business. United has generally very good maintenance and procedures, and unfortunately it had to dual failures here in not getting the required secondary IA sign off, and in not getting the word out quickly enough to the field to prevent the final two flights.