I have 2 ZSE40-700's installed a couple weeks ago, firmware 32.32, on HE v2.3.1.142. I'm testing them for reliability - collecting 100+ data points a day from each - and haven't seen any problems.
Did you upgrade your zwave firmware per this thread? C7 2.3.1 and Z-Wave Firmware 7.17.1 - #66 by bertabcd1234
(Doh! Jeff already asked 
