I did some work on the HEM a couple of years ago by reverse-engineering it to work out what % of loans that the bank I work for writes should be using HEM.
I remember there to be a couple of issues at the lowest end of the pay bracket but I don't remember them to exclude housing. Seems strange that they would change the methodology for the lower bracket.
Happy to be corrected though.
Afterpay Valuation, page-392
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