Here is where your theory completely breaks down. You have never been able to respond to the evidence I have repeatedly placed before you about this very point. If you have replied, I have never read it.
Romans 3:21 expressly teaches that the Law is the manifestation of God's own personal righteousness. That is precisely why we find universal terms are used in Romans 3:9-20 with reference to "the Law" of God.
1. Both Gentiles and Jews - v. 9
2. "none....all...none....all.... - vv. 10-23
3. "all the world....no flesh...every mouth" - vv. 19-20
It is universal not because the Law was given to Gentiles but because it reveals God's own moral nature as Creator over "all the world..every mouth".
Furthermore, the law can be reduced to one MORAL value - love just as God can be summarized by one MORAL value - Love, just as God can be summarized by one MORAL value - LOVE. Therefore the Law is the written MANIFESTATION of God's own righteousness just as Paul says in Romans 3:21 and in other places.
But this is the just the tip of the iceberg concerning your problems with rejecting the Law as the revelation of God's nature.
1. The term "penal" has no meaning apart from LAW - nothing!!
2. There is no "condemnation" apart from LAW and therefore there is NOTHING to base a "penal" or "substitutionary" atonement upon.
3. Your view defines "substitutionary" as we would define "cream substitute" in the place of real cream thus wholly contrary in nature to cream. Moreover, your view would repudiate any penal consequences as "substitutionary" in value as you repudiate what defines such as consequences, and what defines such as penal and therefore the need for substitution at all.
This whole issue of wrath of God and experiencing it in full on the cross seems to be where we are having trouble agreeing, as Brother Jon seems to shy away from all of the terrible things that Jesus felt/experienced due to him being the sin bearer...