The 2016 financial statements of HCG would lead you to think the entire operation is as tight as a drum.  The problem is certainly not in the rules.  Right now no one seems to know how good the mortgage book actually is.  Certainly, from the financial statements everything looks, in my best financial-speak, hunky dory.  For example, the average down payment (or rather homeowner equity) in uninsured mortgages is around 35%.  Better than your 30% number.