Correct me if I'm wrong but I think FCS schools are still D1 so he would need a waiver for them too. IMO, his academic standing is a bigger hurdle for him than getting a waiver from the NCAA. From what we've heard anyway, he's got a whole bunch of ZEROs or incompletes on his last grade report. At least the last time I checked you couldn't gain admission to a new university with the kind of transcript he would show let alone be academically eligible to play sports.
you can play immediately when transferring down to FCS.