I don't think the FAA or the regs observe terms like "Captain" and "F/O".

The regs use terms like PIC and although your contract equates PIC with captain, the regs do not. Ability to " Hold captain" and "Seniority" are not conditions of regulatory compliance.

I think that's true of nautical regs as well. The person in ultimate charge of a vessel is the "Master", even though usually referred to as "Captain".

I won't claim to be an expert by any stretch of the imagination and I've seen some strange things in aviation but in my 18+ years in a major airline 121 training environment, I've never heard of a First Officer giving PC's, recurrent and Captain upgrades.

United used Pilot Instructors (PI's) who were mostly F/O's by seniority, for sim training but they did NOT give check rides, type rides or PC's. They all had to go through a Captain's qualification, type ride and maintain a Captain's qualification during their stint "in the fleet" as a PI.

In other carriers, I've never heard of the scenario you mentioned.

Sounds very "fishy" to me.

G'Luck Mate

They are not part of the initial cadre program.

Correct, the regulation does not state "captain" it states that a simulator check airman must complete all the training required to "serve as pilot in command...in operations under this part (121)".

FAR 121.412 also states that simulator instructors must have completed the same training. The only difference in 121.411 (c), which covers simulator check airmen, and 121.412 (c), which covers simulator instructors, is the requirement in 121.411 (c) for a simulator check airman be approved by the administrator (ie. the Check Airman Letter from the POI).

Still have not found a way around this other than using a 142 certificate to conduct training, either by using a separate training entity all together, or by creating a separate training division that has a 142 certificate like Delta has with Delta Global Services; or by using medically disqualified/past age 65 pilots, who participate in the Line Observation Program. Neither of these are the case with this airline. Most checking events and all recurrent training events are conducted by first officers who have not completed upgrade training (IOE & Fed Ride).

Long story short on this - the basic question is what training is required to serve as PIC in operations under part 121. From FAA legal - PICs under 121 operations are required to have completed all upgrade ground training, flight training and upgrade IOE. Sounds like this is not legal.

Agreed..they all go through the entire Captain upgrade program to include IOE and a line check. They do not give MV or LOE rides. Just your basic sim sessions and FTD's.

I know for a fact that 4 current part 121 regional carriers are using former Comair pilots as check airmen.
I know that some of these pilots are FOs at these airlines, not contract or management pilots. I do not know about all of them.
These pilots bring many thousands of PIC hours to their new airlines in the exact aircraft they were flying at Comair.
Many of them were check airmen at Comair. Some were instructor pilots and some with just vast experience in the CRJ.
Could any of these be the pilots you are referencing?

New part 121? Or maybe a 121 airline already that is branching into new areas?

At my airline FOs are sim check airmen, but they must have completed the upgrade training. In fact all of the instructors who are FOs have completed upgrade training, including the LOE. They have NOT completed upgrade IOE or line check, but I'm not convinced that is required by the reg for simulator check airmen. Clearly it is for line check airmen.

In any case, since holding captain is merely a function of seniority (not experience or merit) then I'm not sure why it would matter if they are an FO or captain. You want the best men for the job, not the most senior men for the job.