With the IMCR, I hear you don't have to fly any instrument approach or be checked by anyone for almost two years. Then you can legally take off, hack through cloud, and fly an approach to a 300ft cloud base?
Sounds like a death rating to me.
Perhaps, if you choose to act stupidly. It's actually just over two years, up to 25 months to be exact. However, that's not much different to a JAA-PPL with SEP(L) class rating, you could choose not to fly for a year and 51 weeks, then jump into your sole-owned aircraft in 3km vis. All perfectly legal, but not sensible or safe.