Just to close the loop on this - we were approved today after our interview at the Seoul Embassy. No waiver required and the interview was super simple and easy. We ended up expediting at the NVC stage because I was working in Singapore but received an offer to transfer back to the US effective on May 1st, so the timing of everything was nearly perfect.
I won’t lie though, the thought of a waiver weighed heavily on my mind for the past month and caused many sleepless nights and countless hours of consultations with ChatGPT. I’m hoping this data point might help others who have a case that lies somewhere in the “gray zone”.