Oh, and yes I advertised as an aerial photographer, and yes I cleared the whole thing with my local FAA FSDO before I flew my first mission. Local interpretations can very so I recommend checking in with your FSDO first.
My interpretation is a commercial rating is required.
I find it interesting that you relied on a government employee to protect you from the government!
Nothing sends a chill down my spine faster than the statement
"I'm from the government and I'm here to help"
John KLWM