Any local club can become a CBO the FRIA just makes it easier in general for the club aspect.
In reality AMA is not needed if each club wanted to become a CBO and filled out the application properly.
A CBO is nothing more than a nonprofit community organization, there are thousands and thousands of them, just about every organization in your local community is a CBO..
As others have said,
in theory.
In reality, however, if you're going to want to be a CBO, I doubt they're going to let just anyone claim to be a CBO for the FAA. I think there's going to be some liability that they're going to have to absorb, especially if they're saying, "We're going to help these people under our organization fly without having to use Remote IDs in our FRIAs." That's that organization taking on liability, whether explicit or implicit, and I can bet that the FAA isn't going to be handing out CBO recognition to just anyone who doesn't want to take on that liability. FTCA saying, "We're not going to be responsible for any accidents by having our members just sign waivers," might not sit well with the FAA.
I'm waiting to see who else gets approved; I'm sure there's going to be others, but looking at the requirements, I can also see CBOs like the Boy Scouts/Girl Scouts of America not getting approved on these items:
(h) Community-based Organization Defined.-In this section, the term "community-based organization" means a membership-based association entity that-
(1) is described in section 501(c)(3) of the Internal Revenue Code of 1986;
(2) is exempt from tax under section 501(a) of the Internal Revenue Code of 1986;
(3) the mission of which is demonstrably the furtherance of model aviation;
(4) provides a comprehensive set of safety guidelines for all aspects of model aviation addressing the assembly and operation of model aircraft and that emphasize safe aeromodelling operations within the national airspace system and the protection and safety of individuals and property on the ground, and may provide a comprehensive set of safety rules and programming for the operation of unmanned aircraft that have the advanced flight capabilities enabling active, sustained, and controlled navigation of the aircraft beyond visual line of sight of the operator;
(5) provides programming and support for any local charter organizations, affiliates, or clubs; and
(6) provides assistance and support in the development and operation of locally designated model aircraft flying sites.
A mission to demonstrably further model aviation could rule out organizations like the Boy Scouts/Girl Scouts, because model aviation is not their main focus and is arguably ONLY a focus for those scouts looking to pursue merit badges or programs in aviation, which may only be once or twice a year or for a very small niche.
Also, publishing a comprehensive set of safety guidelines, which is a huge issue for most people here who just say, "Use common sense", is going to be a sticking point for some. Yes, you will actually have to have rules published that detail a flight line. Yes, you will actually have to have rules for things like having a spotter for FPV. Yes, you will have to have rules posted about putting FAA numbers on your aircraft. You know, all of the rules that many people here are complaining about having to follow...Those sorts of things will put the kibosh on a CBO application.
Lastly, providing assistance and support in the development and operation of locally designated model aircraft flying sites - this means that they would need to show that they are helping to establish flying sites, maintain sites, and show that they are trying to attract new flyers to those locations. Organizations NOT doing that may not be recognized as a CBO.
Does this mean that an organization outside of the AMA couldn't be recognized as a CBO? Absolutely not. There can, and most likely will be, other organizations outside of the AMA that will be recognized. But I can see this being a swamp where people are either going to fight to be recognized, or there's going to be a lot of groups recognized that fall apart after a year or so and are no longer recognized as a CBO, thus taking their FRIA statuses with them.
I say this having worked in the telephone industry for decades, where the FCC let everyone split and create their own phone companies under divestiture. Companies came up, popped up all over, providing phone services for various customers, until they realized that they couldn't make it work, couldn't undercut the bigger companies, and either sold off their services and customers to the larger corporations like AT&T, or they went under and told those customers to find someone else. This is what I see happening to some CBOs. Let's say that "Joe's Flying Club" submits the paperwork to become a CBO. They create a list of rules, they get their tax exemptions, they develop a mission statement, and they go out into the community and set up events and flying areas that the community at large can come in and fly at. Then they apply for and get a FRIA established, and realize, "Hey, this is a heckuva lot of work to maintain!" and decide to fold because they don't want to police their organization to make sure people are following the rules they published, or they no longer qualify for the 501(c) non-profit status, or they no longer want to get out into the community and promote model aviation as one of the requirements for CBO status.
I think there's going to be denials for those "organizations" that are popping up trying to pretend to be a CBO because of that. You don't want to jump through all of the hoops, you're not serious about this, you don't get to play in the sandbox.