Hot N High
That maybe correct but it would be impossible to prove a cloudbase in a court unless you admit it. Even with overcast at 200 feet no one can prove that there was not a hole and tunnel in the clouds leading to the numbers and touchdown point. This appears to be unenforceable law in the above format.
RVR is a different matter and you will get the book thrown at you breaking an RVR minima.
Pace