DVC plans to target commercial renters

[lowlight]

Truly people think Disney has nothing better to do than police reservations with their flat management fee.

It’s not that they have nothing better to do, it’s that they have an obligation to the membership. We know DVC isn’t doing this out of the goodness of their hearts- they are either doing it because it’s costing them money (through room bookings) or it will cost them money (lawsuits brought about by membership for failure to stop egregious violations of contract).

 

[nalababybear]

It’s not that they have nothing better to do, it’s that they have an obligation to the membership. We know DVC isn’t doing this out of the goodness of their hearts- they are either doing it because it’s costing them money (through room bookings) or it will cost them money (lawsuits brought about by membership for failure to stop egregious violations of contract).

Former reason - if it's enough to hit their bottom line to get Csuite to make DVC board to act, yes.

Latter reason - not going to move them. They did DAS reform with much higher visibility and PR risk than DVC membership.

 

[Grumpy by Birth]

The problem is that just identifying who those reservations belong to is not enough. Until the name on that is changed to someone elses name, DVC can not assume they will become actual rentals....if they don't rent, they get canceled.

I agree with just about everything you post, but I'm not convinced that this is necessarily the case.

If someone owns 1000s of points (perhaps spread over multiple membership #s and LLCs, etc.) and they have pages and pages of reservations posted for rent on their website, I think this clearly demonstrates that they are engaged in commercial activity even if those reservations are never actually rented to someone.

Just the act of listing a large number of reservations for rent is enough to establish that they are using their membership commercially. They are attempting to commercially rent the moment they list, regardless of if/when they accept payment for the rental and transfer the name.

 

[AstroBlasters]

It’s not that they have nothing better to do, it’s that they have an obligation to the membership. We know DVC isn’t doing this out of the goodness of their hearts- they are either doing it because it’s costing them money (through room bookings) or it will cost them money (lawsuits brought about by membership for failure to stop egregious violations of contract).

Yeah…. not conceding that your ideas are “better for the membership”….. and DVC would seem to agree.

Repeat after me: frivolous lawsuits should result in the loser paying all court costs and the winner’s attorney fees.

 

[MerlinandtheMouse]

Yeah…. not conceding that your ideas are “better for the membership”….. and DVC would seem to agree.

Repeat after me: frivolous lawsuits should be result in the loser paying all court costs and the winners attorney fees.

How would DVC seem to agree? It’s now well established that DVC is proactively changing the POS of newer resorts to reflect more control over rentals and renting signaling that something’s changed and there is a need for something that wasn’t necessary before.

They’ve also verbally acknowledged that commercial renting has become a problem (I understand they said it’s not widespread) and they’ve committed to a task force to sort the problem out which they’ve said they plan to address this year. All of which they said at a meeting where they know their words are dissected and they know really do matter (Poly Tower association gate, anyone?). This seems pretty pressing to me when they could be focusing their energy anywhere else but policing reservations with their flat management fee, as a PP said. And yet they kind of are doing that. Because I’m not sure how else they’re going address the issue if they haven’t already spent some time (and will continue to spend time) data mining and looking into people’s reservations.

So I’m no expert but I’d say those few, but significant, actions support that DVC does see the current renting culture as a problem. If it wasn’t a serious enough issue that was effecting their bottom line they’d toss the comments aside like they did when some complained about monorail and transportation issues at the Grand Floridian with some flippant response like ‘they’ll keep their eye on it but it doesn’t seem like there’s an issue’.

I agree with those that say DVC won’t make dramatic moves but that’s doesn't mean they’re not going to do anything serious like some posters have assumed. They actually don’t have better things to do. This is something they’ve said they will attempt to alleviate, or at least address, by next year. And they can’t even get a much-need AKV refurb scheduled properly but this task they’ve given a timeline for…idk reads serious to me.

 

[AstroBlasters]

How would DVC seem to agree? It’s now well established that DVC is proactively changing the POS of newer resorts to reflect more control over rentals and renting signaling that something’s changed and there is a need for something that wasn’t necessary before.

They’ve also verbally acknowledged that commercial renting has become a problem (I understand they said it’s not widespread) and they’ve committed to a task force to sort the problem out which they’ve said they plan to address this year. All of which they said at a meeting where they know their words are dissected and they know really do matter (Poly Tower association gate, anyone?). This seems pretty pressing to me when they could be focusing their energy anywhere else but policing reservations with their flat management fee, as a PP said. And yet they kind of are doing that. Because I’m not sure how else they’re going address the issue if they haven’t already spent some time (and will continue to spend time) data mining and looking into people’s reservations.

So I’m no expert but I’d say those few, but significant, actions support that DVC does see the current renting culture as a problem. If it wasn’t a serious enough issue that was effecting their bottom line they’d toss the comments aside like they did when some complained about monorail and transportation issues at the Grand Floridian with some flippant response like ‘they’re look keep their eye on it but it doesn’t seem like there’s an issue’.

I agree with those that say DVC won’t make dramatic moves but that’s doesn't mean they’re not going to do anything serious like some posters have assumed. They actually don’t have better things to do. This is something they’ve said they will attempt to alleviate, or at least address, by next year. And they can’t even get a much-need AKV refurb scheduled properly but this task they’ve given a timeline for…idk reads serious to me.

I am referencing that specific posters dranconian ideas. Someone who states they are fine if the entire membership is harmed as long as they can get their way does not get to start making assumptions that they have any high ground.

 

[HyperspaceMountainPilot]

I had read their posts earlier and feel like 95% of what I have written is compatible with what they have said as long as we are discussing specific measures that Disney would take with regard to defining and restricting commercial use. I agree that Disney can't arbitrarily introduce rental restrictions outside of that context. The only thing I really don't buy is the relevance of the narrow statutory definition of "commercial enterprise" when "commercial purpose", "commercial practice", "commercial enterprise", and restrictions on any use other than "personal use" are all relevant to determining if a use is allowed. I suspect that is where I think Disney has a fair bit of leeway when determining what to do, and why the RIV POS isn't a significant change here.

Yeah, I got the sense that their very narrow definition of commercial practice/purpose was based on wishful thinking more than anything in statute or case law and when I specifically tagged them to ask about what they were basing the unusually narrow definition upon the reply was crickets.

 

[HyperspaceMountainPilot]

Uh oh... goodbye thread about renting, welcome back thread about walking.

I leave for one day, and we almost lost this thread to the walking debate.

We'd probably see resale prices for some resorts dropping, at least temporarily, when those contracts are unloaded.

My main motivation for wanting to stamp out commercial renting is to make it easier for owners with smaller contracts to have a short at low point rooms, but my secondary motivation is hopes I can scoop up more BCV or finally purchase BWV at a bargain basement price— getting either under $80 from a commercial renter would be so sweet.

Maybe, it depends how the contracts are structured if we are talking about 2-4000k points. A 500, 700, or 1k point contract probably wouldn’t hurt the price of 100/200 contract. If there were a bunch of 50-200 point contracts, then we’d see resale prices drop.

This is a good point, need to give some serious thought if I’m willing to commit to another 200 or more points at WDW, because any fire sale is less likely to be happening under 100 points, I suspect, since so many of us would like to add 25-50 points at many of the most rented resorts.

In general I would be OK with it, I just worry what happens if a medical issue comes up, a child has an event at school or a major sports tournament, or some unmovable thing at work past the banking window.

Get rid of the 4m banking window and then it’s workable.

I would love to see the banking window made a bit longer (even 4–>2 months would be a huge improvement!), but I would also like a “banking insurance” type fee where we could pay an extra premium for a booking we feel we might need to cancel to be able to bank if we do need to cancel it. Doesn’t DVC already offer some sort of insurance product?

We should point out that this wording is only included in RIV and later POS documents.

I am not your lawyer (or Disney’s) so this is not technical legal advice, but if I was doing any of the things described in the RIV POS on a regular basis, and needed to do it to “make DVC work for my family” I’d be selling the points I needed to rent every year pronto— you want the buyer’s deposit paid into escrow in your contract before Disney starts sending out letters to the first wave of targets. Isn’t there some chance this process has already started with AUL owners?

I will go farther to say that because they included it here and not in the pre RIV resorts they may recognize they don’t have the authority to actually change things for those resorts as easily as some think they can.

I mean why bother putting all this in to RiV if the discretion they currently have includes all of this?

And why wouldn’t they have amended the other resorts POS to add these additional clarifiers if it within their right to do so?

@Sykes very capably addressed this while I was chasing my kids around AUL, but in summary, Disney already had the ability to stop commercial renting and the new language at RIV and CFW are commercial practices that have come into common practice, so they are spelling them out to curtail some arguments that owners who rent for profit might try to waste everybody’s time making in the future.

It's worth noting that, at least as far as that restriction is concerned, the RIV POS and the earlier POSes that I've reviewed (specifically SSR) are materially the same--they just illustrate examples of the restriction differently.

Both restrict usage to personal use, both explicitly disallow commercial use, and both give the Board broad discretion about how to define commercial and personal use. The only real difference is how they illustrate examples of how Disney might determine that something is commercial (or otherwise non-personal) use. The RIV POS more clearly shows how Disney intends to enforce the restrictions, but IMO Disney has the same tools available at both SSR and RIV.

This this this…and the penguin analogy was awesome as well.

There is one more important difference. Pre-RIV states that DVC must act reasonably in determining whether use is commercial.

RIV onwards give DVC absolute discretion to decide one way or the other.

Otherwise, totally agree with you.

Sykes posted earlier in this thread about how reasonable would probably be read into fiduciary requirements in any event, so I thought I’d take a different tack, drawing from commercial litigation procedure: if Disney decided to prohibit routine activity of the kind @DonMacGregor kindly shared from the RIV documents at any resort, and then took action to punish all members who were regularly spec renting and/or advertising such rentals on 3rd party sites, those owner-renters would have to sue and then convince a judge and/or jury that their practice of reserving highly in demand rooms, to make more income than their annual dues on the points they rented, could not possibly, reasonably be understood as a commercial practice, commercial enterprise, or commercial activity. You might not even make it to a jury because it seems ripe for judgment as a matter of law.

It could also just be DVC using the opportunity to add wording now that they know what the rental landscape is in post-2019.

It doesn’t necessarily mean they don’t think previous contracts have room to step in there, but now they know how things have changed with renting* and are writing/selling new contracts, it was wise be more descriptive.

Legally there always that chance a ruling doesn’t go as expected. The new wording could just be to lower that chance down to zero as close they can, at least for contracts moving forward.

*eta - and stripping/flipping and broker sites getting into the rental/resale action themselves too

This is very well stated. You can feel 100% confident your contract is good enough, but still add another 3 paragraphs to make it even stronger— this is one reason why every time you see clickwrap on a software license it’s like 10 pages of mouse type.

Thank you for bringing up the RIV POS. I think it does give us pretty significant insight into how Disney is thinking about the commercial rental problem, and I suspect that the criteria that they do end up using to evaluate commercial rentals will look a lot like what is listed there.

Agree. I also think it’s the exact kind of thing that 65-90% of the people posting here have stated agreement with (I concede that there is a vocal minority that really doesn’t seem to care about routine spec rentals, but not sure how to quantify if more narrowly than that).

It’s not that they have nothing better to do, it’s that they have an obligation to the membership. We know DVC isn’t doing this out of the goodness of their hearts- they are either doing it because it’s costing them money (through room bookings) or it will cost them money (lawsuits brought about by membership for failure to stop egregious violations of contract).

I think DVC is less worried about lawsuits from members who can’t get certain types of rooms easily and more worried about what percentage of BWV/AKV/BRV studios are going to renters who would otherwise have paid cash to stay on the hotel sides of the properties (and how many people aren’t staying at moderates because they can rent a DVC room for 250-350 instead).

Repeat after me: frivolous lawsuits should result in the loser paying all court costs and the winner’s attorney fees.

Does anybody know what the POS says about owners challenging enforcement (or non-enforcement) and losing? I could see a disgruntled owner bringing suit either way, and if you’re an entity that’s going to go bankrupt if you can’t keep spec renting 500 nights a year you may decide you as well go down swinging?

If each party bears its own costs no matter what, that’s going to stop most random owners with less than 10,000 points from suing, but if winner gets fees reimbursed by the loser, I think DVC (and non-contesting members) are more likely to prevail and have fees reimbursed (again, assuming the other side has enough money to reimburse).

 

[Judique]

I think DVC is less worried about lawsuits from members who can’t get certain types of rooms easily and more worried about what percentage of BWV/AKV/BRV studios are going to renters who would otherwise have paid cash to stay on the hotel sides of the properties (and how many people aren’t staying at moderates because they can rent a DVC room for 250-350 instead).

This.

 

[xdan0920]

Disagree with me all you want but there is no bias in my posts since I do not rent and never plan to…and being a mod does not influence my opinions.

You have been pretty straightforward that you don’t want any major changes. So there is some bias there. However, I was referring to the OP. They are reading the contract in a way they want it to be interpreted, so that’s the bias I was referring to.

 

[xdan0920]

Btw, I am going to WDW the first week of November. I looked on just 1 DVC rental website and found 35 spec rentals already made. And that’s just 1 website. I am sure those people are just changing their travel plans and had no choice but to rent.

 

[Nabas]

Btw, I am going to WDW the first week of November. I looked on just 1 DVC rental website and found 35 spec rentals already made. And that’s just 1 website. I am sure those people are just changing their travel plans and had no choice but to rent.

35 confirmed reservations is not terrible, especially if they are spread across multiple resorts.

At least one rental site has hundreds of confirmed reservations, with about 200 being AKV Value and BWV Standard Studios, the most profitable rentals. (These are listed at about $32 to $42 per point.)

 

[xdan0920]

35 confirmed reservations is not terrible, especially if they are spread across multiple resorts.

At least one rental site has hundreds of confirmed reservations, with about 200 being AKV Value and BWV Standard Studios, the most profitable rentals. (These are listed at about $32 to $42 per point.)

I went to this sites sponser. Not sure where you are looking, perhaps I’ll google it. Aggravate myself some more.

 

[Sandisw]

I agree with just about everything you post, but I'm not convinced that this is necessarily the case.

If someone owns 1000s of points (perhaps spread over multiple membership #s and LLCs, etc.) and they have pages and pages of reservations posted for rent on their website, I think this clearly demonstrates that they are engaged in commercial activity even if those reservations are never actually rented to someone.

Just the act of listing a large number of reservations for rent is enough to establish that they are using their membership commercially. They are attempting to commercially rent the moment they list, regardless of if/when they accept payment for the rental and transfer the name.

See, in your example it’s not the listing of it alone is the trigger, it’s the volume of the listing.

Apply that to an owner like me who currently has 14 reservations across all three of my memberships and my name is on every single one.

Some now have other guests with me, some are split stays, and some are bookings for trips I might take…but not one will be a rental.

Plus, my comment about listing alone not being enough was in reference to enforcement and the potential canceling of reservations on an owner.

Until that name change happens, DVC would be hard pressed to say they had the right to cancel any reservation in an owner’s name.

 

[Sandisw]

I leave for one day, and we almost lost this thread to the walking debate.

My main motivation for wanting to stamp out commercial renting is to make it easier for owners with smaller contracts to have a short at low point rooms, but my secondary motivation is hopes I can scoop up more BCV or finally purchase BWV at a bargain basement price— getting either under $80 from a commercial renter would be so sweet.

This is a good point, need to give some serious thought if I’m willing to commit to another 200 or more points at WDW, because any fire sale is less likely to be happening under 100 points, I suspect, since so many of us would like to add 25-50 points at many of the most rented resorts.

I would love to see the banking window made a bit longer (even 4–>2 months would be a huge improvement!), but I would also like a “banking insurance” type fee where we could pay an extra premium for a booking we feel we might need to cancel to be able to bank if we do need to cancel it. Doesn’t DVC already offer some sort of insurance product?

I am not your lawyer (or Disney’s) so this is not technical legal advice, but if I was doing any of the things described in the RIV POS on a regular basis, and needed to do it to “make DVC work for my family” I’d be selling the points I needed to rent every year pronto— you want the buyer’s deposit paid into escrow in your contract before Disney starts sending out letters to the first wave of targets. Isn’t there some chance this process has already started with AUL owners?

@Sykes very capably addressed this while I was chasing my kids around AUL, but in summary, Disney already had the ability to stop commercial renting and the new language at RIV and CFW are commercial practices that have come into common practice, so they are spelling them out to curtail some arguments that owners who rent for profit might try to waste everybody’s time making in the future.

This this this…and the penguin analogy was awesome as well.

Sykes posted earlier in this thread about how reasonable would probably be read into fiduciary requirements in any event, so I thought I’d take a different tack, drawing from commercial litigation procedure: if Disney decided to prohibit routine activity of the kind @DonMacGregor kindly shared from the RIV documents at any resort, and then took action to punish all members who were regularly spec renting and/or advertising such rentals on 3rd party sites, those owner-renters would have to sue and then convince a judge and/or jury that their practice of reserving highly in demand rooms, to make more income than their annual dues on the points they rented, could not possibly, reasonably be understood as a commercial practice, commercial enterprise, or commercial activity. You might not even make it to a jury because it seems ripe for judgment as a matter of law.

This is very well stated. You can feel 100% confident your contract is good enough, but still add another 3 paragraphs to make it even stronger— this is one reason why every time you see clickwrap on a software license it’s like 10 pages of mouse type.

Agree. I also think it’s the exact kind of thing that 65-90% of the people posting here have stated agreement with (I concede that there is a vocal minority that really doesn’t seem to care about routine spec rentals, but not sure how to quantify if more narrowly than that).

I think DVC is less worried about lawsuits from members who can’t get certain types of rooms easily and more worried about what percentage of BWV/AKV/BRV studios are going to renters who would otherwise have paid cash to stay on the hotel sides of the properties (and how many people aren’t staying at moderates because they can rent a DVC room for 250-350 instead).

Does anybody know what the POS says about owners challenging enforcement (or non-enforcement) and losing? I could see a disgruntled owner bringing suit either way, and if you’re an entity that’s going to go bankrupt if you can’t keep spec renting 500 nights a year you may decide you as well go down swinging?

If each party bears its own costs no matter what, that’s going to stop most random owners with less than 10,000 points from suing, but if winner gets fees reimbursed by the loser, I think DVC (and non-contesting members) are more likely to prevail and have fees reimbursed (again, assuming the other side has enough money to reimburse).

One piece of language not missing from the RIV POS was commercial enterprise. And the way they phrased things there is a bit different…that part may mean nothing,,,but the attachment to commerical enterprise IMO does.

Even as a RIV owner, I still contend that clause allows renting except as a business. Now, they definitely added more clarifiers as to what they can use to determine commercial enterprise when they decide to enforce.

But, DVC and DVC lawyers made the choice to change the declaration and make it much more specific for those buying.

And that begs the question for me as why? Why do that if you are confident you have the authority to do it anyway? Why did they not just update that language to the rules for other DVc resorts? If they already have the right to use that instead of what is written, why not simply make them all match?

I agree that nothing is stopping DVC from taking the stance that since it’s in RIV we can use it for all resorts and an owner, like me, who doesn’t think they can without a change to POS, has to fight them legally.

My opinion is still that if this was a slam dunk for DVC and they can do all of this already, then there had to be a reason behind that change and I contend it was a legal one.

Because if the notion is it was only ti just make the contract clearer, then I think they would have wanted to do that for all owners by updating things in writing for them as well.

Now, if DVC updates rules for owners with this language, then it answers the question IMO that they think they can withstand a challenge.

Obviously, as I said, different legal analysis of it and only DVC lawyers know which one matches.

Just to be clear, I have always said they can add other things to their determination…so they can say that you have a pattern and you do XYZ which is further proof…but what I don’t think they can do for owners at pre RIV is take out the need for a pattern, that whatever they do needs to be reasonable and that they need to conclude you are a commercial enterprise.

Harder for RIV owners to fight they are not a commerical enterprise.

One thing I know for sure is that my SSR and VGF POS state that the board has adopted a definition or rules regarding it and that record can be viewed upon request.

I have done that and will do it in person if that is what is required of me.

If that record no longer applies, then they will have to tell me it doesn’t and whether or not their is a new one in place.

We shall see where it goes.

 

[Nabas]

See, in your example it’s not the listing of it alone is the trigger, it’s the volume of the listing.

Apply that to an owner like me who currently has 14 reservations across all three of my memberships and my name is on every single one.

Some now have other guests with me, some are split stays, and some are bookings for trips I might take…but not one will be a rental.

Plus, my comment about listing alone not being enough was in reference to enforcement and the potential canceling of reservations on an owner.

Until that name change happens, DVC would be hard pressed to say they had the right to cancel any reservation in an owner’s name.

Similar to you, I currently have 13 reservations but they all have the same last name (include my children and sister) so I doubt these would interest Disney.

I think this is where the (now removed) 20 reservation limit clause kicked in. I suspect when they wrote that clause, Disney planned to review all members with more than 20 reservations over a 12-month period, requiring the member to satisfy Disney that these 20 were for personal use. But it was a clumsy approach and Disney apparently abandoned it.

There are more sophisticated methods to identify renters. For example, start with DVC memberships owned through LLCs and trace these to the ultimate owners.

Rather than chase after DVC members with small side businesses renting a few hundred points for extra income, I suspect Disney wants to go after those who are renting points on an industrial scale, those who are blatantly abusing the commercial purposes clause.

 

[New Mouse]

Let's be realistic about the past, when it comes to DVC at least. Disney lawyers have done a terrible job assuming things were legal and to Disneys benefit that obviously were not.

Disney tends to write a lot about how they want things to be, but when it comes to actually being enforceable it almost never is.

 

[Sandisw]

Similar to you, I currently have 13 reservations but they all have the same last name (include my children and sister) so I doubt these would interest Disney.

I think this is where the (now removed) 20 reservation limit clause kicked in. I suspect when they wrote that clause, Disney planned to review all members with more than 20 reservations over a 12-month period, requiring the member to satisfy Disney that these 20 were for personal use. But it was a clumsy approach and Disney apparently abandoned it.

There are more sophisticated methods to identify renters. For example, start with DVC memberships owned through LLCs and trace these to the ultimate owners.

Rather than chase after DVC members with small side businesses renting a few hundred points for extra income, I suspect Disney wants to go after those who are renting points on an industrial scale, those who are blatantly abusing the commercial purposes clause.

People keep saying that DVC no longer uses that but we really have nothing from DVC that they don’t.

It did exist but after going over previous posts on this topic last night, it didn’t exist in the POS.

It existed outside of it because of the assertion the POS can’t be changed by DVC unilaterally.

I still wonder if that document is the report that was referenced in the SSR and VGF POS as existing and being available for review by owners.

So, I don’t think it’s fact that they have rescinded those rules of what triggers things…for RiV and beyond, I’d say it’s a likely situation but the whole it’s moot or gone for the other resorts?

Nothing from DVC has ever supported that.

 

[Sandisw]

You have been pretty straightforward that you don’t want any major changes. So there is some bias there. However, I was referring to the OP. They are reading the contract in a way they want it to be interpreted, so that’s the bias I was referring to.

I have but so have you and everyone else who has weighed in. I personally don’t consider it bias but if you do, then we are all biased.

If the person I cited is doing that, making the case because they want it that way, then all the lawyers who have weighed in are doing that as well.

My point was and still is that they have extensive background in this, and in particular in reviewing DVC, and that analysis says something different than other legal experts who have also weighed in.

My interpretation of the contract is supported by that persons legal knowledge and other posters feel the other legal knowledge fits.

I have posted many times….the only one’s interpretation that matters is DVCs…they get to decide what they can legally do or at least legally support.

And my guess is that what they will do is go after the LLCs and owners who have reached that 8000 limit and call it a day.

 

[DonMacGregor]

There are more sophisticated methods to identify renters. For example, start with DVC memberships owned through LLCs and trace these to the ultimate owners.

I was going to mention this yesterday, but forgot. Another interesting addition to the CFW POS language is this phrase (introduced twice):

5.7 Except for Ownership Interests owned by DVD, rentals of Vacation Homes to the general public by any of The TWDC
Companies including DVD and BVTC, reservation or use of Vacation Homes and facilities of a DVC Resort is limited solely to the
personal use of Club Members, their guests, invitees, exchangers, and lessees and for recreational use by corporations or other similar
business entities owning Ownership Interests while staying as a registered guest at the DVC Resort. Except for any of The TWDC
Companies, purchase of an Ownership Interest and reservation or use of Vacation Homes and facilities of a DVC Resort for
commercial purposes or for any purpose other than personal use is expressly prohibited. BVTC shall be the sole determiner, in its
discretion, of any use or activity that does not constitute personal use or constitutes commercial use under this Agreement. Such
commercial purpose could include a pattern of rental activity of reserved Vacation Homes or frequent occupancy by others of reserved
Vacation Homes other than a Club Member or the Club Member's family; use of regular rental or resale advertising; creating,
maintaining, or frequent use of a rental or resale website; repeated or frequent purchase and resale of Ownership Interests whether in
the name of a Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts; or the
acquisition of a number of Ownership Interests in excess of the amount of the maximum permitted ownership whether in the name of a
Club Member or those related to such Club Member or through the use of entities, partnerships, or trusts.

Which suggests to me that they are wise to efforts made to circumvent rental and points ownership limits by means of LLC’s, etc., a scheme many of us suspected has become more commonplace in recent years (and apparently Disney recognizes it too).