Firstly my apologies, a vessel longer than 45 feet or that goes beyond 3 miles of shore is a Class XII vessel of the Merchant Shipping Regulations and not a SOLAS Class XII vessel. So it seams in the US you don’t have to have a liferaft. The regulation says ‘US flagged yachts, no matter what there size, that are for private use only (recreation vessels), do not have to carry a life raft.

However SOLAS, which you wrongly state only concerns the safety of merchant ships. Has clauses in it for all vessels, including pleasure craft. The main area that affects pleasure craft is SOLAS V: Safety of navigation. Particularly regulations: V19, 29, 31, 32, 33, 34 and V35. There are some other non safety regulations else where.

TJ has all the answers, risk aversion x trade-off. And, is operating within the law. I sure hope he never has to put his plan in place.

The facts, at sea, are the same the world over.
Weather changes, often suddenly and a lot worse than predicted.
Vessels malfunction or break down.
Atmospherics interfere with coms.
People fall or get swept overboard.
Other vessels can’t see boats or people in high seas.
People in the water may not be able to reach each other, let alone see each other.
People in high seas may struggle to catch there breath and open their eyes.
In seas of 7C/45F people’s survival time is estimated to be between 40 and 80 mins.
Cold will have rendered them useless after 7 to 14 mins at 7C/45F.
An immersion suit would expand survival times to between 6 & 8 hours at this temp.
Larger vessels with more sophisticated equipment and trained crew may recognise worsening weather conditions and move out of storm track. Taking them away from small vessels, that may need their assistance at a later time.
Aircraft flight operations may be affected by bad weather; rescue may have to come from a surface vessel.
Even with GPS enabled 406 Mhz Epirb could still mean being in the water for several hours.