That's kinda like saying "I don't care what the cops think, I want to know what the judge says." Coast Guard regulations are not "what the Coast Guard thinks", it is the law. The court will uphold it if necessary. When someone buys a ticket at an auction, that person becomes a paying customer. In order to take a paying customer out on your boat, you must have, at the least, an OUPV license. And the comment "even if you don't directly benefit.." Is somewhat incorrect, because a donation to a charity in addition to usually being a tax write off (a direct benefit), is essentially giving your income for that event to the charity, i.e., even tho you're giving your compensation away, you are still required to comply with the law as regards paying passengers. In the same vein, you can own and drive your own limousine, but if you want to charge for the vehicles services (or donate them to a charity), you'll need a chauffeur's license along with the appropriate insurance.