The 20 rental thing is not an inviolable rule and if LLC’s are structuring to “get around it” then Disney will adapt. Again, if large companies creating LLC’s to structure purchases around the 20 limit rule solely for the purpose of buying, stripping, renting, and selling is not “commercial use,” than nothing is. It’s certainly not “personal use.”
To the earlier question of “who is getting hurt?” I’m not naive enough to believe Disney will really get involved until Disney starts getting hurt. But with soft hotel bookings right now, and soft DVC sales, outfits like
DVC Rental Store are absolutely competing against Disney themselves, and that’s going to get noticed.
Also, all these complex new rules that people are proposing is almost certainly not going to be the route Disney goes, nor are they going to take some kind of costly legal action. They’re just going to start warning and then ultimately cancelling reservations. That’s all they need to do. Why would they do anything more?