OscarMeyr wrote:
The conventional meaning of what a pending draw is, does nothing to address how a pending draw may be satisfied. On this basis, I am still inclined to rule FALSE.

Sounds reasonable to me.

R101 does NOT say Jack Risk about what regulated actions may be performed, or under what conditions.

I think that's a feature.  In general, you don't regulate something
by merely declaring "X is hereby deemed to be regulated" without
further context. Rather, you say "X may be performed under these conditions" which is evidence that X is regulated and may NOT
be performed outside of those conditions.  Its "the exception
proving the rule" in the original legal sense of the phrase.

-Goethe

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