[RPG] What “level” is a monster, for the Tough feat

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It seems that if a couatl changes shape into a humanoid, it can get racial features. But if it decides to turn into a variant human and picks the Tough feat, is its level its CR (4) or its number of hit dice (13)? What if it changes into a mage that specifies it's an "x-level spellcaster"? (I know it wouldn't get spellcasting, but if this feat would normally be unavailable for creatures without levels, would doing this give it a usable level?)

This actually probably applies in exactly the same way to the less-complicated situation of "NPC humanoid, what's its level?" but maybe it's different?

Best Answer

The Change Shape feature does not work in this way

The Couatl's Change Shape feature states:

The couatl magically polymorphs into a humanoid or beast that has a challenge rating equal to or less than its own, or back into its true form [...]

The Couatl thus cannot turn into a variant human because that is a Player Character race option, and thus does not have a challenge rating.

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