I don't know about it being a DOT requirement on seat belts for each sleeping position or not. In my Super C in its original configuration it had the capacity to sleep 10 people. 2 in the King bed, 2 bunk beds, 2 dinette sleeping, 2 sofa sleeping, and 2 in over cab sleeping area. There were only seat belts for 7 people. Our rear facing dinette seat has no seat belts.
We had the bunk beds eliminated and wardrobe installed along with the sofa bed now has theater seating instead. So only need 2 seat belts anyway as it is just the 2 of us traveling.
