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Aggregation of Data Risk

From the NYT Oct. 12, 2015 by Patricia Cohen on gaming by for-profit colleges to protect their indirect financing via student loans through the U.S. Dept. of Education (and the U.S. taxpayers):

  • “…even schools with egregious violations have become adept at exploiting loopholes, sidestepping rules or taking advantage of yearslong (sic) appeals processes. Companies with several campuses can pool graduation, financial, enrollment, staffing and other statistics to mask weak performers…”

This may be seen in other contexts too as even fraudulent enterprises such as Enron reported many transactions accurately and completely. Aggregation of data is a wonderful way to bury things, creating composite averages and account balances that tend to demonstrate normalcy in reporting (or close enough to it). The cliche of ‘pigs getting fed and hogs getting slaughtered’ as a strategy to evade fraud detection by the usual suspects (e.g., auditors, regulators) is common and effective. Even when it fails it may add years to the lifecycle of a fraudulent scheme, providing fraudsters an opportunity to escape with riches and reputation while the music still plays.

Attorneys, accountants, and other service providers (cf. facilitators) with an excess in creativity and client advocacy skills and deficiency in ethics and reality-tolerance capacities too often get exorbitantly rewarded for behavior that tends toward the shadowy side where integrity is measured by how much one can get away with.

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