It is whether the appropriate authorities agree with this analysis of the regulations and whether they have the concern and motivation to do anything about it, that counts
WM,
This is well said. However, It goes beyond an analysis that is the initiative of a professional individual. On several occasions official documents with PJ stamps were transmitted to authorities bearing proofs that PJ commercially operated N-registered aircraft that had not been put on their AOC. Aircraft details, flight details, names of passengers and destinations were all mentioned in said documents. What actions were taken? The answer can be concluded by PJ continuing to commit this plus other numerous violations.
Anyway, it is amuzing how PJ management referred to their clients as "guests" in an attempt to cover their fraudulant practices.