exclusions sometimes have "incontestability provisions" which limit the ability of the mortgage insurer to deny coverage for misrepresentations attributed to the policyholder if twelve consecutive payments are made, although these incontestability provisions generally don't apply to outright fraud. Coverage can be rescinded if misrepresentation or fraud exists. In 2009, the United States District Court for the Central District of California determined that mortgage insurance could not be rescinded "poolwide". History Mortgage insurance began in the United States in the 1880s, and the first law on it was passed in New York in 1904. The industry grew in response to the 1920s real estate bubble and was "entirely bankrupted" after the Great Depression. By 1933, no private mortgage insurance companies existed. The bankruptcy was related to the industry's involvement in "mortgage pools", an early practice similar to mortgage securitization. The federal government began insuring mortgages in 1934 through the Federal Housing Administration and Veteran's Administration, but after the Great Depression no private mortgage insurance was authorized in the United States until 1956, when Wisconsin passed a law allowing the first post-Depression insurer, Mortgage Guaranty Insurance Corporation (MGIC), to be chartered. This was followed by a California law in 1961 which would become the standard for other states' mortgage insurance laws. Eventually the National Association of Insurance Commissioners created a model law. Max H. Karl, a Milwaukee real estate attorney, invented the modern form of private mortgage insurance. In the 1950s, Karl became frustrated with the time and paperwork required to obtain a home backed by Federal Government insurance, the only kind available at the time. In 1957, using $250,000 raised from friends and other investors in his hometown of Milwaukee, Karl founded the Mortgage Guaranty Insurance Corporation. Unlike many mortgage insurers who collapsed during the Depression, MGIC would only insure the first 20 percent of loss on a defaulted mortgage, thus limiting its exposure and creating more incentives for savings and loan associations and other lenders to issue loans only to home buyers who could afford them. The guarantee was enough to encourage lenders across the country to issue mortgage loans to buyers whose down payments were less than 20 percent of the home's price. The availability of credit helped fuel the home building boom of the 1960s and 1970s. By the time of Karl's death in 1995, more than 12 percent of the nation's nearly $4 trillion in home mortgages