Flying Club Advertising

For starters, Discovery Flights are exempt from the TSA's flight school regulations.  From their web site:
Another question is whether your club's insurance allows for provision of such flights to non-members.  You might want to review your policy or speak with your insurer about that.

As for FAA regulations, as long as it is conducted as a Discovery Flight, I see no problem with it.  In order to be such a flight, it must be conducted by a CFI who holds Commercial/ATP and CFI certificates, and the trainee is provided with a logbook documenting the training IAW 61.51 and 61.189(a).  See this legal interpretation for details.

Thank you very much! My next call was going to be the insurance company already. I appreciate the input!

Hello Jim.  Steve Bateman here, AOPA Director of Flying Clubs.  I’ve pondered your post and have come to the conclusion that, like many things in aviation, it is a probable maybe!
I see many moving parts here – the fact that it is a non-profit flying club (rather than a commercial operator), whether you operate from a publicly funded airport, whether this is compensation-in-kind, whether the aircraft had a 100-hour inspection in the previous 100-hours of use, and so on.  I’d be pleased to discuss this more with you at your convenience.  (301 695 2356).
Also, if you are a member of AOPA Pilot Protection Services (https://pilot-protection-services.aopa.org/), please feel free to call in and discuss this with one of AOPA’s lawyers. (800 872 2672).
 

Please see FAA Order 5190.6B, chapter 10, section 6:
https://www.faa.gov/airports/resources/publications/orders/compliance_5190_6/
Also, the amendment:
https://www.federalregister.gov/documents/2016/03/15/2016-05833/petition-of-the-aircraft-owner-and-pilots-association-aopa-to-amend-faa-policy-concerning-flying

As I mentioned, there are many circumstances to consider - no "one-size-fits-all", so suggest people call in to AOPA PPS.

My apologies -- I had two different threads confused.  What I said in my initial reply stands.  The FAA and TSA regulations on flight training and Discovery flights are well established and described in the interpretation letter I referenced.  The club's corporate structure is irrelevant,  The fact that the club is receiving free advertising in return is not significant because it is completely legal to provide flight training in return for compensation without a commercial operating certificate -- 14 CFR 119.1(e)(1).  And yes, per 14 CFR 91.409(b), 100-hour inspections absolutely will be required because the club is providing both the aircraft and the instructor.  But if the club is currently providing flight training to members with club instructors, they should be doing that already.