Prior to the updated policy,
DVC themselves, based on enforcement and what owners were told, they did indeed allow people to have all 20 be in the names of others.
That is why I think this updated policy is more specific because DVC has decided they want to enforce differently .
Because the old 2011 policy said enforcement didn’t kick in until after 20, and DVC only acted when above 20, the implication was it didn’t matter.
Now, this new policy is clearer of DVCs intent..and why I mentioned earlier, what I was always advised,,,that written policy matters and that if they want to enforce the policy language needs to be clear….IMO, that is a big reason why this is now as detailed as it is for owners.
While it still gives DVC discretion when evaluating at the individual owner level, it gives pretty specific examples of what triggers things and all the potential consequences that can occur.