The three points come from the FAA's own Part 61 FAQ (all 19 pages of it).
The author of the FAQ was
John D. Lynch, Certification Branch, AFS 840, Washington, DC
[email protected]
(202) 267-3844
The frontispiece to the FAQ contains the following from the Director, Flight Standards Service, FAA:
"There is a disclaimer statement at the beginning of each of these websites that state the answers are not legal interpretations. Only the FAA's Office of Chief Counsel and Regional Chief Counsel provide legal interpretations. However, it is important that our personnel be aware of these websites. I want it understood that the answers and information provided on these websites are official FAA Flight Standards policy about Part 61, Part 14, and Part 142."
Unfortunately, none of the FAQs referred to in the above are now publicly available, presumably because the FAA recognized that the FAQs were in a legal middle ground, not legal interpretations but nonetheless official FAA Flight Standards policy.
The copy I have is dated June 2004, and I think it unlikely that FAA interpretation of 61.75 could have changed so much since then. Some evidence that it hasn't is provided by the proposed changes to 61.75.
If you Google Part 61 FAQ you'll be able to find a downloadable copy somewhere out there.