Excellent Robert!!! You know I've done a lot of research about this exact same thing.  I don't think we've heard the end of it.  HUD has trippled it's "investigation team" and I think we are going to see many many many more audits in all areas of this industry by HUD/FDIC/FTCetc.  I'm sure that it's going to take a while before they finally come up with a general idea and enough amo for congress to accept HUDS position on this however I foresee these "ducks" paying the "bill" eventually.

I like you say...don't do it.

Adrienne