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Btw just curious. What makes you guys think it is a ms 65 or 66?
A (perceived) relative lack of marks on the coin. The problem with this type of toning is that it can be very good at disguising underlying marks, which PCGS would have seen with the coin in-hand. I see a line from the "A" of Gratia through the "R" of Rex, two lines on the King's neck, lines heading outward to the rim both above and below the nose, and possibly some roughness on the lowest part of the neck. It's impossible to tell if these are toning disturbances or actual marks on the coin from a static photo.
It has a solid 65 "look" to it (IMO), but if PCGS knocked it down to a 64 I'm not inclined to doubt their assessment.