Yeah I think this is to counter someone selling theirs on purpose replacing it. Guess the number is just honestly an estimate of what could reasonably happen, but then it’s still 3 a year. But then again you couldn’t definitely have such bad luck to lose your wallet thrice a year.

Anyways, I’d assume that if (well before the US went totally mad) there was an actually reasonable case of someone encountering the limit who clearly wasn’t a fraudster, it’d probably be amended.

But that’s just my cursed optimism, probably doesn’t reflect reality.