> Sure, if you bend over backwards and squint through one eye, you can contort yourself into the bad faith interpretation that developers will be treated as brokers--given they can engage in "transfers."

Pardon me for having a legal education and knowing that prosecutors are often more than willing to bend over backwards and squint through one eye.

If it's possible for a prosecutor to argue it, they will eventually argue it, and most of the time the courts won't push back.