When we think of the debates surrounding linguistic transfer in L3 acquisition, one of the most prominent discussions concerns whether transfer occurs in a wholesale fashion or whether it is property-by-property. One such model is the Linguistic Proximity Model (LPM, Mykhaylyk et al., 2015; Westergaard et al., 2017; Westergaard, 2021), which maintains that transfer is property-by-property, with what Westergaard refers to as Full Transfer Potential (FTP). Westergaard injects the notion of complexity at each stage of development and recognizes the need to determine how a range of variables drive outcomes across these different stages. With that said, there are a set of points in the proposal that we believe are short of explanatory logic and will benefit from further consideration; we focus on two here. The first regards the need to go beyond post-hoc explanations of non-facilitative transfer via a commitment to a testable, proposal for when the LPM predicts such transfer will occur. The second relates to the current trend of using existing data to support property-by-property versus wholesale transfer. We contend that this application of existing data is an unsound practice because these data are in fact compatible with multiple theoretical accounts.