2 two-seater fighter trainers were converted from P-39Q-20s, and were designated RP-39Q-22. Serials were 44-3879, 3885, 3886, 3887, 3889, 3895, 3897, 3905, 3906, 3908, 3917, and 3918.

The canopy and the ventral fin were different in shape from that of the original TP-39Q-5 and TP-39F. The nose wheel had an unusual disk with holes, instead of the flat one of the single-seater P-39Q.