But suppose the insurance company isn't involved, ie it's not a requirrment? And suppose the club rules simply state that you can't fly solo after 28 days, but need a competent pilot in the other seat. In other words, they're not saying you can't be PIC, just that you need a safety pilot. What then?
Oooo, isn't this fun? A perfectly simple piece of flying activity that goes on every day of the week, and we can argue about it for ever and ever.