jmt-
The way I've read this situation is that you must have the card to work on a C10's payroll even if you hold a C10 yourself. But, as you say, if you sub contract from another C10 on a 1099 basis you are in compliance with the law as long as you hold a C10 yourself. But it is too bad you didn't get your card before the deadline because that would give you all the options.

electure-
It can also be a sweet deal for the one man show like myself(I like it that way for now). It's an option I haven't had to use it yet but if I get so buried that I need help for a couple of days to stay on schedule I could sub out to my former employer. Not him personally because he doesn't have the card but he could send one or two of his guys( my old buds) over. I have both the card and the C10 so I can reciprocate either way. I know I would lose some profit doing it that way but hey, it's not always about the money...right?
I don't see anything wrong with this if we assume the intent of the program was to insure that working electricians are experienced and have passed qualifying exams.(as opposed to being another way for govt. to exert control over us while taking our money)