Its good that the world doesn't sit around and wait to see what "RST
believes"!
I know of serveral pilots that have worked for a well known firm in
Napa that offers rides to pax, including aerobatics, including letting
the pax try some aerobatics themselves. None of them are CFIs. The
operation is in good graces will the FAA. If you can think of any reg
that you think prohibits this you should consider posting it.