RWY EXCURSION BY A PA23 WITH 3 PAX ON BOARD THAT LATER THE FSDO DETERMINED WERE POSSIBLY ON BOARD UNDER AN ALLEGED ILLEGAL PART 135 OP; LNDG AT TEB; NJ.

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ON LNDG AT TEB; THE ACFT DEPARTED RWY 19 AT LOW SPD AFTER TOUCHDOWN; POSSIBLY DUE TO A MALFUNCTIONING L BRAKE; COUPLED WITH A STRONG R XWIND. NO INJURIES WERE SUSTAINED BY ANY OCCUPANT OF THE ACFT; AND ONLY MINOR DAMAGE WAS DONE TO THE ACFT. DURING THE SUBSEQUENT QUESTIONING BY THE LCL FSDO; THEY DECIDED THAT THIS FLT MAY HAVE BEEN OPERATED UNDER RULES WHICH WOULD GOVERN PART 135 OPS. THIS RPTR; THE OWNER/PLT OF THE ACFT; HAD THOUGHT TO HAVE BEEN CONDUCTING THE FLT UNDER PART 91. THE PAX HAD CALLED THE PREVIOUS DAY TO ASK IF I WOULD BE IN THE AREA; AND IF I COULD TAKE THEM DOWN TO GAI FOR A MEETING THAT HAD SUDDENLY BEEN CALLED. THE COMPANY CEO WAS A FRIEND OF THE OWNER/PLT'S MOTHER. DURING THESE INITIAL CONTACTS; IT HAD BEEN MADE CLR TO THE COMPANY CEO THAT I WAS NOT A PART 135 'CHARTER' OPERATOR. I; HAD HAD PREVIOUS PLANS TO BE IN NJ AROUND THIS TIME TO VISIT FRIENDS AND RELATIVES; INCLUDING A SIDE-TRIP TO VA. I INFORMED THE COMPANY OWNER THAT I WOULD BE HAPPY TO TAKEN THEM TO THEIR MEETING; AS IT WOULD BE A CHANCE FOR MORE FLYING TIME; AND A VISIT TO A NEW ARPT. AN OFFER OF REIMBURSEMENT FOR THE OPERATING COSTS OF THE ACFT WAS MADE BY THE COMPANY OWNER; BASED ON THE HOURLY COSTS OF THE ACTUAL COSTS OF AIRPLANE OWNERSHIP AND FLT. THIS OFFER WAS NOT ACCEPTED FOR THIS FLT. HOWEVER; ON THE ONE PREVIOUS FLT THAT HAD TAKEN PLACE; WITH THE SAME COMPANY CEO; THE SAME OFFER HAD BEEN MADE AND ACCEPTED; UNDER THE IMPRESSION THAT SO LONG AS NO PROFIT WAS BEING MADE; AND SO LONG AS THE TRIP WAS PRIMARILY MEANT AS A FRIENDLY GESTURE TOWARDS A FRIEND; THERE WAS NO VIOLATION OF THE PART 135 REGS OCCURRING. SINCE THE LCL TEB FSDO PEOPLE HAVE BECOME INVOLVED; I HAVE DONE ADDITIONAL RESEARCH INTO THE REGS THAT GOVERNED THIS OR THESE FLTS. I HAVE FOUND THAT THE REGS LEAVE A LARGE GAP OF 'GRAY AREA' REGARDING WHAT A PVT-RATED PLT CAN DO REGARDING SHARED EXPENSES; AND WHAT A LICENSED PART 135 OPERATOR MAY DO. THERE IS NO SPECIFIC GUIDANCE GIVEN. THE ISSUE OF REIMBURSING THE COST OF THE ACFT; AND HOW MUCH IS ACCEPTABLE TO THE FAA; AND WHETHER ACCEPTING A FLT IN ANSWER TO A FRIENDLY REQUEST CONSTITUTES 'HOLDING ONESELF OUT' FOR CHARTER IS VERY AMBIGUOUS IN MY OPINION. I DID NOT ADVERTISE MYSELF IN ANY WAY AT ANY TIME. THIS RPTR FEELS THAT THIS SIT COULD HAVE BEEN AVOIDED IF THE FAR'S WERE ADDED TO; WITH WORDING SPECIFICALLY ADDRESSING WHAT IS AND IS NOT ACCEPTABLE FOR BOTH FLT; AND REIMBURSEMENT FOR COST; WHERE SIMILAR CIRCUMSTANCES EXISTS. MANY OTHER FAR'S ARE SPECIFICALLY WRITTEN IN THE NEGATIVE; BUT THE PART 135 RULES THAT HAVE BEEN ALLEGEDLY BROKEN ARE ALL WRITTEN FOR PART 135 OPERATORS; DESCRIBING WHAT THEY ARE ALLOWED AND NOT ALLOWED TO DO. NOTHING SEEMS TO EXIST SPECIFICALLY STATING WHERE THE LIMITS LIE PRIOR TO ACTING AS A PART 135 OPERATOR WITHOUT THE APPROPRIATE CERTIFICATE. HAD THIS BEEN MORE CLR; I WOULD NOT HAVE ACCEPTED THE ORIGINAL FLT-COST REIMBURSEMENT; AND POSSIBLY NOT HAVE DONE EITHER FLT; REGARDLESS OF THE 'FAVOR FOR MY MOTHER'S FRIEND' DIMENSION.