No loophole that I see. These are all 4th year students. Not only would they have to sit out, but they would run out of eligibility once they were done sitting.
What about Russel Wilson of Wisc? Isn't there a rule you can transfer, play in your 5th year without sitting out as long as you already got your degree at the previous school? I could be completely wrong but just throwing out that example. I really doubt we'd be able to get that large of an amount of players from ND and they would all be able to play right away. Even if we did, it only serves as a 1-year Philadelphia Eagles-like fix. Stack with players that don't mesh well and backfires.
I've talked to Gerry several times and he never mentions anything. Just an overall positive guy and great person that loves UA. If anything the arena and conference talks are a lot more intriguing but really don't believe them much.