All valid comments, but it makes everything more difficult for those of us who aren't playing games. I recognise that my extension is probably one of the easiest in the world, but the requirements are becoming more pedantic and exacting to line everything up as they require.
The 400k year 'round was ostensibly to stop agents. That requires the cooperation of an IO, but I never heard about them going after the facilitators - they just punished the rest of us with the 400k requirement.