Ethics

I write about lawyers' obligation of fidelity to law, by which I mean the law as it ought reasonably to be interpreted.  This is meant to exclude the exploitationn of loopholes from ethical lawyering.  Of course, I am always having to articulate criteria for what constitutes a loophole, as opposed to a reasonable interpretation of the law.  I'm curious, does anyone think the following is NOT a loophole:

Recent federal legislation prohibits the use of the word "census" on a mailing that is actually a soliciation for funds.  Specifically, here is section (b) of H.R. 4621, the Prevent Deceptive Census Look Alike Mailings Act:

Matter Soliciting Information or Contribution of Funds-- Section 3001(i) of title 39, United States Code, is amended--

(1) by inserting, in the matter preceding paragraph (1), `; or which bears the term `census' on the envelope or outside cover or wrapper' after `such matter by the Federal Government'

After this legislation took effect, the Republian National Committee sent out another wave of fundraising mailings labeled "census document."  The rationale?  The word "census" is not on the envelope or outside cover -- rather, it is visible in a clear glassine window through the envelope (h/t TPM). 

One assumes a lawyer was asked whether this mailing complies with the law.  Would it be ethical to advise the client, the RNC, that the mailing did not violate the new legislation?  (I'm writing a paper about good faith legal advising, so I ask this question entirely seriously.)