> If a host does not follow the entire OCILLA playbook in every case, unconditionally, across the board, the host no longer qualifies for any safe harbor whatsoever.
The 512(c) safe harbor rules are clearly written in a transaction-specific manner rather than the way you describe, and every case I've seen on them has focussed on whether they were followed as relevant to the transaction and not addressed whether the host followed them "unconditionally, across the board". So, I think your conclusion is wrong.
The 512(c) safe harbor rules are clearly written in a transaction-specific manner rather than the way you describe, and every case I've seen on them has focussed on whether they were followed as relevant to the transaction and not addressed whether the host followed them "unconditionally, across the board". So, I think your conclusion is wrong.