FLR Qs

Hi there, I was wondering if anyone could help me with some questions about FLR. Nothing too major. Firstly, my wife came over on May 4th 2015 and the visa runs out on the 13th January 2018. Can she not apply for a new visa until 16th December 2017, as that would be 28 days before it expires? ("The earliest you can apply is 28 days before your current permission (called ‘leave to remain’)") I had been thinking you could apply 28 days before 2 1/2 years was up, which would be 4/11/2017, but is that not the case?

Secondly she passed the Cambridge FCE back in October 2014 at B2 level. From what I understand it this is still valid under section 32D of the immigration rules even though IELTS is the only valid current test.

Thank you in advance.

HR