Originally Posted by
rickair7777
You are his employee. This has nothing to do with holding out...
Holding out is making it known to the public or a segment of the public that you will work for them (advertising, soliciting, word-of-mouth, etc).
You are allowed to "hold out" in search of employment as a pilot...to fly an airplane provided by the customer (what you do). You cannot hold out to operate an airplane provided by you unless you have a 135/121 cert (there a few exceptions such as photo and sightseeing).
Great explanation.
Misunderstanding "holding out" seems to be a general problem in understanding the dividing lines between 91 and 135/121. People talk about it as though "holding out" is some sort of evil and that any time you "hold out" you are violating some reg.
Your explanation makes it much clearer: "holding out" is a test for whether or not you are making your services available. That's all. The only time it comes into play is when you are performing a service that the regs don't permit you to perform for the public. Then "holding out" becomes part of the proof that your services were meant for the public.