This is correct. I had random groups of four, so theoretically, the top 16 ranked owners would be spreads into four divisions. Then next four would be split into four divisions, etc. But there would always be some tweaking going on in order to get the commissioners to work out. Giving the top 16 a quick glance, I see that...
Only 3 of the top 16 are 1-A (but #17 is in 1-A)
Only 3 of the top 16 are in 2-B (but #17 is in 2-B)
Only 3 of the top 16 are in 3-B (but #17 is in 3-B)
Only 3 of the top 16 are in 4-B (but #17 is in 4-B)
Only 3 of the top 16 are in 5-C (the next ranked 5-C is #21, but #23 and #24 are also 5-C)
League 6 is equally split (4 each A, B, C, D in the top 16)