Correct. Fraud is fraud, loopholes are loopholes. One is legal, the other is not. Or put another way - a loophole in law/regulations is found, then the law/reg

Correct. Fraud is fraud, loopholes are loopholes. One is legal, the other is not. Or put another way - a loophole in law/regulations is found, then the law/regulation gets changed to close the loophole. If it were not legal this change would not be necessary - you would just prosecute.