To the layman it would appear so. However, as I stated, specifically only to certain records--not all records. But the reason behind 419 was to ensure the continuity of those specific records to the next owner and the ability to perform the requirement of 417(c). It's all inclusive. Been there. Got the T-shirt. Made the movie. And the sequel.that's a bit different than not passing the maintenance records to the purchaser
However, everybody is entitled to there opinion...