It’s not a "theory" but facts, as much as you want to make it a theory. The form he used was the previous from, I know that, but they want plausible deniability to be saying the new regulations were already in place but the new form wasn’t ready yet, when they realized the old Form-401 and regulations prohibited second and third-hand hearsay as a basis for instigating an ICIG action. It stands to reason the ICIG would not want to be in the position of chasing unsubstantiated Office rumors, so such reports are summarily prohibited if not supported by first-hand knowledge. Otherwise the ICIG would be flooded by rumor mongers reporting coworkers out of spite.
It is also a known fact that ICIG dated his letter to the chairs of the House and Senate oversight Committees, complaining of how this whistleblower complaint was handled by the DNI and DOJ, on the same day the he first received the complaint, two weeks before he ever submitted the matter to his superior, his new, as yet to be appointed boss—the two weeks he was supposed by statute to be investigating the complaint—who was the new DNI who would take office three days later, and would, after receiving the ICIG’s report, by statute have seven days to review it and make a decision about whether it was an "intelligence community urgent matter" required to be brought to the committees’ attention or not.
Instead, we know ICIG Atkinson wrote and signed his complaint letter about the political handling of the Whistleblower’s complaint despite the written advice from: his own IC legal counsel; his boss’s—the DNI—decision, based on the DNI’s legal counsel’s legal determination; and the further determination of DOJ’s legal counsel staff’s ruling, all concluding that the President was not a member of the Intelligence Community, was therefore not under the statute in question, and was therefore not under ICIG Atkinson’s legal jurisdiction, was in fact explicitly excluded by definition in the statute from such jurisdiction, and it was therefore not an "intelligence community urgent matter," requiring the attention of the Intelligence Oversight committees. But, Atkinson had predetermined his course of action, or rather it had already been scripted for him, given the date on his letter to Chairman Schiff and his Senate counterpart. . . and Atkinson reported it anyway, because that was the role puppet Atkinson was to play in sloppy playwright Schiff’s pre-written script, a script with so many holes in the plot they had to make last minute ad hoc cutting room edits, ala new regulations and new Form.
This doesn't make any sense.
The whistleblower stated that he had direct knowledge so it doesn't matter whether they used the old or new regulations.
You say the WB didn't have direct knowledge, but :
"As part of his determination that the urgent concern appeared credible, the Inspector General of the Intelligence Community determined that the Complainant had official and authorized access to the information and sources referenced in the Complainant’s Letter and Classified Appendix, including direct knowledge of certain alleged conduct..."
It is also a known fact that ICIG dated his letter to the chairs of the House and Senate oversight Committees, complaining of how this whistleblower complaint was handled by the DNI and DOJ, on the same day the he first received the complaint
How is this known? The WB complaint went to the Office of the ICIG on August 12th. The first letter to Schiff & Nunes was dated September 9th.
Your arguments about the various legal opinions from the DNI and DOJ might matter if the ICIG had not heeded them and instead forwarded the complaint to Congress, but he didn't.
Despite being given the authority to determine urgency he deferred to the Administration's wishes and didn't transmit the complaint, so again your point is moot.