Gordy-
I don't know if he did or didn't violate a particular rule paragraph of the FARs and can't be bothered to look. All I'm saying is that if there was a rule violation, there's no meaningful action that can be taken by the FAA against the model if she doesn't hold an airman certificate. If the airman feels he's exercising good judgment doing what he's doing, I suppose that's his business if the FAA doesn't find any rule violation.
What I do know is that the status of the pilot's airman certificate as published on the certification website does not match the standard format, which normally tends to indicate a reaction of some kind on the part of the FAA, which is why I said draw your own conclusions.
The indications on the Airman Certification website are analogous to when a pilot has an alcohol incident, and a similar statement is appended to the information on the pilot's medical.
I believe this is done for the benefit of any potential employers doing due diligence.