Saying you're John Doe and you're a pilot is not holding out. Saying you're John Doe, you're a pilot and you'll fly them to Denver or where ever they want to go is certainly starting down that path.
The simple way to think of it as jcaplins says if you're providing common carriage, you need a 121 or 135 certificate.
However, like prostitution in most jurisdictions, just making the offer is a violation. Shows intent.