Whilst not directly related to the RPT issues here, in the US the "brokering" of charter flights thru sometimes up to three or four parties away from the actual operator of the flight is very much on foot and the subject of new regulations and very much increased regulatory oversight.
The principle though remains the same "is the person or entity from whom you are buying your air transport services the person or entity who holds the actual Certificate and in direct control of the flight you have bought.
It is a growing problem in OZ charter with some "apparently" large and impressive multi aircraft organisations "booking" large amounts of work and often taking large fees, being no more substantial than a well designed website and having as much "control" over the conduct of the flight as Mickey Mouse.
