I'm writing from my phone again...so please excuse me
ZEFFY...the DOT is the worst of all government beauracracies...so if the FAA can find a reason for enforcement they will...although i can think of any enforcements as described...when i read some other action taken by the faa i just would be surprised...so it's just my best guess at what they may do...but i wouldn't chance...i think 91 operators should at least try to make the DP oei...just sounds responsible to me..
FPOBN...I have not seen TEB since 07 iirc....but Im not sure what you mean regarding sully???....:-)