A cardinal $\kappa$ is regular if (and only if) the union of fewer than $\kappa$ many sets of size less than $\kappa$ still always has size less than $\kappa$. That seems to be exactly what you have here. Also, the union of downward closed sets remains downward closed, so you don't need to take the downward closure of the union, as it is already downward closed.
Joel David Hamkins
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