This is also not the correct place to look.

The original no-action letter is after the discussion was had, and everyone was already on the same page, so of course that wouldn't be the place where they explained their premise.

Twice in a row you've looked in a place nobody would ever put it, and said "well it's not there, so I guess nobody ever explained it."

This conversation holds no value to me. If you choose to be unable to find this wholly documented thing, so be it.

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> Nothing in any of the letters has anything resembling justification

You've only looked in two places for an explanation, and they're both after the decision, where an explanation would never be.

Once this could be excused as a simple mistake, but you circled back around and did it again with a bright light already shone on the mistake.

Good luck to you.