This is the 2018 Statute regulating Timeshares in Florida. Since (disclaimer!) I'm not a lawyer, I can only try to interpret this massive document to my best understanding.
The biggest problem is that this document mostly refers to traditional timeshares, sold in weeks for specific units, not for points timeshare like DVC. So it cannot be applied literally to our case.
In the Florida statute, a Timeshare Unit is defined as:
"Timeshare unit” means an accommodation of a timeshare plan which is divided into timeshare periods. Any timeshare unit in which a door or doors connecting two or more separate rooms are capable of being locked to create two or more private dwellings shall only constitute one timeshare unit for purposes of this chapter, unless the timeshare instrument provides that timeshare interests may be separately conveyed in such locked-off portions.
In the DVC Public Offering Statement document (POS) (I own only the SSR - Saratoga Springs Resort one, but others are similar or identical), Units are something completely different, as they are portion of a resort, sometime including a whole building or a whole floor. To find something matching the Florida Law definition of a Timeshare Unit we have to look at Vacation Homes:
Vacation Home shall mean and refer to those portions of a Unit designed and intended for separate use and occupancy.
The two definition clearly match. I guess it's just marketing, very much like DVC is a "Vacation Club" and not a timeshare, the rooms are called Vacation Homes and not Timeshare Units.
This interpretation is reinforce by how studios and 1 bedroom are defined in the SSR POS:
Studios Vacation Home shall mean a Vacation Home containing one (1) bedroom, one (1) bathroom and equipped with a microwave, under counter refrigerator, and sink.
One-bedroom Vacation Home shall mean a Vacation Home containing one (1) bedroom, one (1) bathroom and a full kitchen.
SSR does not have any dedicated studio or 1 bedroom (1BR), so those definitions have to apply to the locked off portions of a 2 bedrooms (2BR) lockoff.
This means that every rule that refers to a Timeshare Unit in the Florida Law applies to the locked off studios and 1BR.
In particular, the most important rule of all, the “One-to-one use right to use night requirement ratio”.
"No individual timeshare unit may be counted as providing more than 365 use nights per 12-month period"
The meaning of this law is clear for traditional timeshares: a developer cannot sell 500 nights corresponding to a one timeshare units and let buyers fight for bookings. How this translates into point timeshares brings us in muddles waters. My interpretation is that the requirement translates into:
The number of points needed to book a Timeshare Unit over the whole Use Year cannot exceed the number of points declared for the Timeshare Unit.
If it were possible to ask for more points, over the year, that the points that the timeshare units is declared for, it would be like a developer selling 365 nights, but then ask to consume 2 nights for each one booked (and use the remaining nights for cash bookings).
My conclusion: the 2020 reallocation moved points between different Vacation Home types: this is not permitted by the Florida Law, because it violates the one-to-one use right to use night requirement ratio.