Greg:
Existing old "FPE" 150 amp panel. EC adding three (3) new 2 wire circuits. He installs a 60 amp, 2 pole FPE CB, 1" EMT raceway (3'6"), 5' +/- conductor length. into a 100 amp MLO new sub panel. Three compliant AFCI CBs in new sub panel. Normal TR devices.

IMHO, that is compliant, and the AFCI receptacles are not required. Agree??


John