You have misunderstood, they have said it's unfair if FMV interest rates aren't included in the PSR calculations. Your statement "unlawful if they aren't included" demonstrates this, you were claiming that shareholder loans were being used to prop up clubs to meet PSR this would mean they WERE included.
The transfer analogy was regarding you saying that they are unfair because other clubs don't have shareholder loans, nobody is stopping them from getting some so you can't blame other clubs if your owners aren't prepared to provide them!