I think (though might well be misunderstanding) that reckless disregard is taken to be an intentional choice but that it does not imply that the outcome itself was intentional. The difference between intentionally doing something that you know for a fact has a high risk of failure but you can't necessarily predict the outcome versus intentionally seeking a particular legally disallowed outcome.

But what LPisGood was saying is that reckless disregard (as opposed to explicit intent) is sufficient to meet the legal bar for fraud.