2013-04-04 Nonprofit Fraud: Part I

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In Part I of our Three-Part Nonprofit Fraud Seminar, you will learn about: Why you need to be educated about fraud in your organization. A few statistics and facts about fraud and nonprofits. Who commits fraud and why. Common types of fraud in nonprofits. Three case studies involving common nonprofits fraud schemes and Important takeaways!

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2013-04-04 Nonprofit Fraud: Part I

  1. 1. Nonprofit Fraud: What You Need to Know Part I: The Fraud Lawrence J. Hoffman, CPA/CFF, CVA, CFE Senior Partner, & Director of Forensic Consulting Services April 4, 2013Thrive. Grow. Achieve.
  2. 2. OBJECTIVES NONPROFIT FRAUD: THREE-PART SERIESPART I: THE FRAUD• Why it is important that you are educated in fraud• The magnitude of fraud in nonprofits• The types of frauds in nonprofits• Why does fraud occur in nonprofits• Some important fraud prevention measuresPART II: THE DETECTION• Who are the fraud perpetrators?• Why do people commit fraud?• How is fraud detected?• What are fraud red flags?• Fraud detection techniques• What do you do when you uncover fraud?PART III: THE PREVENTION• What are the primary factors contributing to fraud in nonprofits?• Detective versus preventative controls• What are the best preventative measures?• The five critical takeaways! Part I: The Fraud * Page 2
  3. 3. AGENDA• Why you need to be educated about fraud• What you need to know about the impact of fraud• Common types of fraud in nonprofits• Case study # 1• Case study # 2• More case studies• Summary – the important takeaways!• How can Raffa assist you in preventing and detecting fraud?• Resources and suggested reading• Questions and answers Part I: The Fraud * Page 3
  4. 4. WHY YOU NEED TO KNOW ABOUT FRAUD THE TOP TEN REASONS!1. Nonprofit organizations are very susceptible to fraud and abuse1. Don’t count on your outside auditor to uncover the fraud2. Fraud increases when the “pressure / incentive” increases, which increases in a poor economy1 and layoffs (fewer employees doing more)3. You probably have some sort of fraud in your organization going on and you don’t know it4. A fraud in your organization could bring unwanted outcomes, such as adverse publicity, loss of support, lower employee morale, and disruption of your operations1 See article, “In Tough Economy, Employee Theft Climbs to Epidemic Proportions, Expert Says,” Statesman.com, November 2011. Part I: The Fraud * Page 4
  5. 5. WHY YOU NEED TO KNOW ABOUT FRAUD THE TOP TEN REASONS! (CONTINUED)6. The IRS requires you to disclose instances of fraud – Form 990 – more transparent to donors7. You cannot afford the loss, cost of the investigation, and disruption to your operations8. Asset (cash ) misappropriations are by far the most prevalent frauds committed against nonprofits and the most important resource9. The fraud perpetrator is not easily known to the organization. In many cases, the perpetrator is “someone you know and trust”10. You could find yourself personally liable for damages Part I: The Fraud * Page 5
  6. 6. WHY YOU NEED TO KNOW ABOUT FRAUDFORM 990 RETURN OF ORGANIZATION EXEMPT FROM INCOME TAX Part I: The Fraud * Page 6
  7. 7. WHAT YOU NEED TO KNOW ABOUT FRAUDGo to http://www.acfe.com/rttn.aspx to download the report. Part I: The Fraud * Page 7
  8. 8. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS• Typical organization loses 5% of its annual revenue to fraud (applied to 2011Gross World Product = $3.5 trillion)• Median loss is $140,000• Fraud lasted 18 months before being detected• 87% are asset misappropriation schemes• Most likely detected by a tip than any other means• Small organizations are disproportionately victimized• Most occupational fraudsters are first-time offenders with clean employment histories. Approximately 87% of occupational fraudsters had never been charged or convicted of a fraud-related offense, and 84% had never been punished or terminated by an employer for fraud-related conduct• In 81% of cases, the fraudster displayed one or more behavioral red flags that are often associated with fraudulent conduct. – Living beyond their means (36%) – Experiencing financial difficulties (27%) – Unusually close association with vendors or customers (19%) – Excessive control issues (18%) Part I: The Fraud * Page 8
  9. 9. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED)• Perpetrators with higher levels of authority tend to cause much larger losses. The median loss among frauds committed by owners / executives was $573,000, the median loss caused by managers was $180,000, and the median loss caused by employees was $60,000• The longer a perpetrator has worked for an organization, the higher fraud losses tend to be. Perpetrators with more than 10 years of experience at the victim organization caused a median loss of $229,000. By comparison, the median loss caused by perpetrators who committed fraud in their first year on the job was only $25,000• 77% of all frauds in the study were committed by individuals working in one of six departments: accounting, operations, sales, executive / upper management, customer service, and publishing• Nearly half of victim organizations do not recover any losses that they suffer due to fraud. 49% of victims had not recovered any of the perpetrator’s takings; this finding is consistent with previous research, which indicates that 40-50% of victim organizations do not recover any of their fraud-related losses Part I: The Fraud * Page 9
  10. 10. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED)• Not-for-profit organizations made up the smallest portion of the ACFE’s dataset, accounting for more slightly more than 10% of reported cases Part I: The Fraud * Page 10
  11. 11. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 11
  12. 12. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED)• Small organizations (those with fewer than 100 employees) continue to be the most common victims in fraud Part I: The Fraud * Page 12
  13. 13. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 13
  14. 14. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 14
  15. 15. WHAT YOU NEED TO KNOW ABOUT FRAUD ACFE REPORT TO THE NATIONS SUMMARY OF FINDINGS (CONTINUED) Part I: The Fraud * Page 15
  16. 16. WHAT YOU NEED TO KNOW ABOUT FRAUD CONCLUSIONS AND RECOMMENDATIONS• Occupational fraud is a global problem• Fraud reporting mechanisms (hotlines) are a critical component of an effective fraud prevention and detection system• Organizations tend to over-rely on audits• Employee education is the foundation of preventing and detecting fraud• Surprise audits are an effective, yet underutilized tool• Small businesses are particularly vulnerable to fraud• Internal controls alone are insufficient to fully prevent fraud• Fraudsters exhibit behavioral warning signs of their misdeeds• Effective fraud prevention measures are critical Part I: The Fraud * Page 16
  17. 17. WHAT YOU NEED TO KNOW ABOUT FRAUD JP SIMS CONSULTING – CASES REPORTED IN LAST SIX MONTHS IN THE NONPROFIT SECTOR• “Brooklyn Woman Sentenced in Manhattan Federal Court to Two Years in Prison for Participating in $57.3 Million Fraud on Organization that Makes Reparations to Victims of Nazi Persecution”• “Former President and Executive Director of Vanguard Public Foundation Sentenced to 40 Months in Prison for Fraud and Money Laundering”• “Monroeton Woman Sentenced for Embezzling Money from Martha Lloyd Community Services”• “A.G. Schneiderman Announces $2.3 Million Settlement with St. Luke’s-Roosevelt Hospital for Overbilling Medicaid and Medicare”• “Miami-Area Therapist Sentenced to Prison in Florida in $205 Million Community Mental Health Fraud Scheme” www.jpsimsconsulting.com Part I: The Fraud * Page 17
  18. 18. WHAT YOU NEED TO KNOW ABOUT FRAUD NONPROFIT FRAUD• Why nonprofits face a disproportionate level of fraud: – Lack of internal controls / segregation of duties – Lack of tone at the top / oversight – “volunteers” vs. “the store owner – Lack of hiring – due diligence – Lack of anti-fraud programs – Too much reliance on audits to catch fraud – More “mission” driven versus “profit” driven – Greater culture of “trust” Part I: The Fraud * Page 18
  19. 19. WHAT YOU NEED TO KNOW ABOUT FRAUD THE SIZE OF THE NONPROFIT SECTOR2 • 1,551,705 tax-exempt organizations composed of: – 963,255 public charities – 97,941 private foundations – 490,509 other types of organizations (e.g., chambers of commerce, fraternal organizations, and civic leagues) • Nonprofits’ share of the U.S. GDP was 5.5% in 2012 • In 2010 (the most recent date in which these figures were aggregated), public charities accounted for: – $1.51 trillion in revenue • Of the revenue, 22% came from contributions, gifts, and government grants; 73% came from program services revenues, which include government fees and contracts; and 5% came from “other” sources, including dues, rental income, special event income, and gains or losses from goods sold • In 2011(the most recent date in which these figures were aggregated), private charitable contributions, which include giving to public charities and religious congregations, totalled $298.4 billion2 National Center for Charitable Statistics, “Quick Facts about Nonprofits,” http://nccs.urban.org/statistics/quickfacts.cfm. Part I: The Fraud * Page 19
  20. 20. WHAT YOU NEED TO KNOW ABOUT FRAUD THE MOST IMPORTANT POINTS YOU WILL TAKE AWAY FROM THIS SEMINAR SERIES• Design your systems and procedures so you do not have to rely on trust as a control!• Any person is capable of committing fraud!• TRUST IS NOT AN INTERNAL CONTROL! Part I: The Fraud * Page 20
  21. 21. FAMOUS QUOTES “Trust, but verify.”• 40th President of the United States Ronald W. Reagan (1911-2004) “Verify, then verify some more.”• Senior Partner, Raffa, P.C., Lawrence J. Hoffman, CPA/CFF, CVA, CFE (1954-?) Part I: The Fraud * Page 21
  22. 22. MY BOOK!EXPECTED RELEASE THIS FALL! STAY TUNED! Part I: The Fraud * Page 22
  23. 23. WHAT YOU NEED TO KNOW ABOUT FRAUD THE FIVE MOST IMPORTANT TAKEAWAYS1. Trust is not an internal control! – Establish, to the extent possible, controls and procedures that eliminate the element of trust – Always segregate the custody of the asset with the recordkeeping for the asset2. Set the tone from the top! – “If you are stealing, your employees are stealing!” – E.g., office supplies, expense reports, etc.3. Know your employees! – Background investigations and public records checks before hiring – Meet and establish a baseline relationship4. Institute a fraud policy – No tolerance – Will prosecute5. Establish a hotline for tips – Number one method for detecting fraud! – Can outsource Part I: The Fraud * Page 23
  24. 24. TYPES OF FRAUD THREE BROAD CATEGORIES OF FRAUD• Fraudulent statements• Corruption• Misappropriation of assets Part I: The Fraud * Page 24
  25. 25. TYPES OF FRAUD Part I: The Fraud * Page 25
  26. 26. TYPES OF FRAUD FRAUDULENT STATEMENTS• Fraudulent financial reporting (“cooking the books”). Intentional misstatement or omissions of amounts or disclosers in financial statements designed to deceive financial users when the effect causes the financial statements not to be presented , in all material respects, in conformity with GAAP – Examples: • Falsification of accounting records • Omissions of transactions or disclosers• Non-Financial – Employment credentials – Internal and external documents Part I: The Fraud * Page 26
  27. 27. TYPES OF FRAUD CORRUPTION• Schemes that involve the employee’s use of his or her influence in business transactions in a way that violates their duty to the employer and obtains benefit for themselves or others: – Conflicts of interest – Bribery – Illegal gratuities – Economic extortion Part I: The Fraud * Page 27
  28. 28. TYPES OF FRAUD MISAPPROPRIATION OF ASSETS• The theft of an entity’s assets where the effect of the theft causes the financial statements not to be presented in conformity with GAAP (sometimes referred to as “defalcation”)• Misappropriation of assets can be accomplished in various ways, including: – Embezzling – Stealing assets – Causing an entity to pay for goods or services that have not been received or causing an entity to overpay for goods or services actually received Part I: The Fraud * Page 28
  29. 29. TYPES OF FRAUD MISAPPROPRIATION OF ASSETS• Revenue and cash receipts (collections) schemes: – Cash skimming / unrecorded sales / contributions – Cash larceny – Lapping schemes – Write-off of accounts receivable – Unauthorized credits – Check tampering (stolen, altered) Part I: The Fraud * Page 29
  30. 30. TYPES OF FRAUD PURCHASING AND CASH DISBURSEMENT SCHEMES• Fictitious invoices and vendors (shell company)• Check tampering – Forged maker (check signer) – Forged endorsement – Altered payee• Bank wire transfers Part I: The Fraud * Page 30
  31. 31. TYPES OF FRAUD PAYROLL AND EMPLOYEE EXPENSE REPORTING SCHEMES• Payroll schemes – Ghost employees – Falsified hours and wages – Overtime abuses• Expense reimbursement schemes – Mischaracterized expenses – Overstated expenses (altered receipts) – Fictitious expenses (bogus receipts) – Multiple reimbursements Part I: The Fraud * Page 31
  32. 32. TYPES OF FRAUD NONCASH ASSET MISAPPROPRIATIONS• Misuse of assets for personal use• Inventory Part I: The Fraud * Page 32
  33. 33. CASE STUDY # 1The Washington Post, Wednesday, June 3, 2009. Part I: The Fraud * Page 33
  34. 34. CASE STUDY # 1 WHAT WENT WRONG?• Position of perpetrator: Controller• Length of time employed: 3 years, 11 months• Length of time fraud lasted: 3 years, 6 months• Schemes involved in fraud: – Fraudulent checks and wire transfers – Used electronic signatures and signature stamps – Falsified accounting of transactions in books and records – Provided forged documents, including bank statements, to independent auditors• How was the fraud discovered?: Executive Director found checks written to perpetrator and an unknown bank account statement in his office after he was terminated for poor performance Part I: The Fraud * Page 34
  35. 35. CASE STUDY # 1 HOW MUCH DID IT COST?• Organization’s annual budget: $2.7 million• Total fraud loss to the organization: $425,558 (fidelity bond was only $30,000 with $5,000 deduction)• Other losses to the organization: Disruption to operations and legal and forensic consulting fees• Where did all the money go?: New 2006 BMW 325i car, furniture, vacations• What happened to the perpetrator?: – Criminal prosecution – Conviction – 41 months in Allenwood, a low-security correctional institution in White Deer, PA – Ordered to pay restitution of $470,990.59 Part I: The Fraud * Page 35
  36. 36. CASE STUDY # 1 LESSONS LEARNED• Lack of segregation of duties – a “one-man show”! – Segregate the custody of the asset with the recordkeeping!• Lack of oversight controls and financial reviews, including review of financial statements, reconciliations• Use of signature stamp• Inadequate fidelity bond coverage• Too much trust and not enough verification! Part I: The Fraud * Page 36
  37. 37. CASE STUDY # 2ORGANIZATION CURRENTLY UNDISCLOSED Part I: The Fraud * Page 37
  38. 38. CASE STUDY # 2 WHAT WENT WRONG?• Position of perpetrator: Director of Information Technology• Length of time employed: 7 years, 7 months – voluntarily left employment and left country• Length of time fraud lasted: 7 years, 5 months• Schemes involved in fraud: – Billing scheme – shell company – billed for IT equipment that was never received by the organization• How was the fraud discovered?: – Whistleblower – person who replaced perpetrator notices discrepancies and anomalies in past IT inventory and procedures Part I: The Fraud * Page 38
  39. 39. CASE STUDY # 2 HOW MUCH DID IT COST?• Total fraud loss to the organization: $3.5 million ($1.3 million recovered from insurance)• Other losses to the organization: Disruption to operations and forensic consulting fees• Where did all the money go?: Amusement park in foreign country• What happened to the perpetrator?: Fled the country Part I: The Fraud * Page 39
  40. 40. CASE STUDY # 2 LESSONS LEARNED• Lack of internal controls / segregation of duties – No separation of custody of asset with recordkeeping• Lack of a packing and receiving reports match• One person controlled the procurement, receipt, and deployment of the assets• Lack of inventory controls – “The wolf watching over the hen house”• Too much trust and not enough verification! Part I: The Fraud * Page 40
  41. 41. MORE CASE STUDIESThe Washington Post, May 31, 1997. Part I: The Fraud * Page 41
  42. 42. MORE CASE STUDIESThe Washington Post, August 17, 2011. Part I: The Fraud * Page 42
  43. 43. MORE CASE STUDIES The Blog of Legal Times, September 26, 2013. Part I: The Fraud * Page 43
  44. 44. MORE CASE STUDIESThe Washington Post, May1, 2010. Part I: The Fraud * Page 44
  45. 45. MORE CASE STUDIESThe Associated Press, January 14, 2013. Part I: The Fraud * Page 45
  46. 46. MORE CASE STUDIESThe National Law Journal, January 14, 2013. Part I: The Fraud * Page 46
  47. 47. MORE CASE STUDIESThe Associated Press, September 24, 2008 Part I: The Fraud * Page 47
  48. 48. MORE CASE STUDIESThe Washington Examiner, July 1, 2010. Part I: The Fraud * Page 48
  49. 49. MORE CASE STUDIES Part I: The Fraud * Page 49
  50. 50. WHAT YOU NEED TO KNOW ABOUT FRAUD THE FIVE MOST IMPORTANT TAKEAWAYS – AGAIN!1. Trust is not an internal control! – Establish, to the extent possible, controls and procedures that eliminate the element of trust – Always segregate the custody of the asset with the recordkeeping for the asset2. Set the tone from the top! – “If you are stealing, your employees are stealing!” – E.g., office supplies, expense reports, etc.3. Know your employees! – Background investigations and public records checks before hiring – Meet and establish a baseline relationship4. Institute a fraud policy – No tolerance – Will prosecute5. Establish a hotline for tips – Number one method for detecting fraud! – Can outsource Part I: The Fraud * Page 50
  51. 51. HOW CAN RAFFA ASSIST YOU IN PREVENTING AND DETECTING FRAUD? FORENSIC CONSULTING SERVICES• Pre-hire investigations and background checks• Fraud risk assessment• Internal control / program review• Fraud awareness training• Fraud prevention programs and policies implementation• Due diligence investigations• Fraud investigations Part I: The Fraud * Page 51
  52. 52. SOME AREAS WE WILL BE GOING OVER IN OUR FINAL PRESENTATIONPART II: THE DETECTION – MAY 7, 2013, 12:00-2:00 P.M.• Who are these people that commit fraud?• Why do they commit fraud?• How are most frauds really detected?• Specific things you should have in place to help detect fraud• What should you do when you uncover fraud?PART III: THE PREVENTION – JUNE 5, 2013, 12:00-2:00 P.M.• What are the primary factors contributing to fraud in nonprofits?• Detective versus preventative measures and controls• The best preventative controls and practices• The critical takeaways and how to implement them Part I: The Fraud * Page 52
  53. 53. RESOURCES AND SUGGESTED READING• 2012 Report to the Nations on Occupational Fraud and Abuse, Association of Certified Fraud Examiners, http://www.acfe.com/rttn.aspx• “The American Fraud Report,” www.jpsimsconsulting.com• The CPA’s Handbook of Fraud and Commercial Crime Prevention, AICPA• Managing the Business Risk of Fraud: A Practical Guide; AICPA, ITA, and ACFE; https://na.theiia.org/standards- guidance/Public%20Documents/fraud%20paper.pdf Part I: The Fraud * Page 53
  54. 54. QUESTIONS AND ANSWERS Part I: The Fraud * Page 54
  55. 55. BIOGRAPHY • 35 years of consulting, audit, accounting and tax experience in the public and private sectors. • Started career with a Big-Four international accounting firm in Washington, DC. • Founded a regional certified public accounting and consulting firm in 1982 and grew it toLAWRENCE J. HOFFMAN, on of the Washington, DC’s largest firms in seven years. Merged his practice with RaffaCPA/CFF, CVA, CFE P.C. in 2008. • Managed and conducted audit and accounting engagements ranging from small privately held to large publicly held businesses in various industries, including multi-national businesses, nonprofit organizations, and governmental entities and agencies. • Performed economic and financial analysis, including projections and forecasts, in support of litigation and claims for lost earnings and profits, business interruption, shareholder disputes, patent and trademark infringements, bankruptcy and restructuring, and structural settlements; assistance with interrogatories, document requests and depositions; and serving as an expert and consulting witness. • Performed and supervised business valuations for both public and closely held companies in a variety of industries, individuals and estates, family limited partnerships and limited liability companies, including valuations for business combinations (SFAS 141R), mergers,SENIOR PARTNER acquisitions, and divestitures, estate and gift taxes, marital dissolution proceedings, buy-RAFFA, P.C. sell agreements, intangible assets and intellectual property, purchase price allocations,1899 L STREET, NW goodwill (SFAS 142) and long-lived asset (SFAS 144) impairment, fair value accountingWASHINGTON, DC 20036 (SFAS 157), cheap stock (IRC 409A), stock-based compensation (SFAS 123R), phantom stock and employee stock ownership plans.TEL. 202-822-5408FAX 202-822-0669 • Conducted and led teams of forensic accountants on fraud audits and investigations,LHOFFMAN@RAFFA.COM including fraudulent financial statements, misappropriations of assets and embezzlements; money laundering, kickbacks, bribery and conflicts of interest; insurance claims; bankruptcy; financial institutions and loan fraud. Also has conducted fraud risk assessments, anti-fraud programs, and fraud training and education. Part I: The Fraud * Page 55
  56. 56. BIOGRAPHY • Assisted companies and nonprofits with restructuring and turnaround situations, including recapitalizations, reorganizations and liquidations. Advised entities on Chapters 11 and 7, bankruptcy filings and proceedings and non-judicial workouts. Developed and administered crisis management plans, cash flows, liquidation and turnaround analysis, debt restructuring and creditor negotiations, and turnaround plans.LAWRENCE J. HOFFMAN,CPA/CFF, CVA, CFE • Formulated strategic short- and long-term business and financial planning for various business organizations and served as interim “C” level positions, including for a major North American sports league, European and U.S. aircraft manufacturer, aviation charter airline and travel company, and a multi-chain quick service food chain. • Formulated syndication strategies and prepared business plans and private placement offerings, including financial forecasts, market research and analysis, due diligence, securities pricing and structuring for various public and private securities offerings, including SEC filing. • Founded and developed a regional NASD licensed broker dealer investment banking firm. Placed over $150 million in debt and equity and represented over $200 million in merger and acquisition transactions. • Founded and developed two private equity funds in excess of $10 million, includingSENIOR PARTNER investments in early stage and mature emerging companies in the form of debt and equity. Portfolio investments included aviation, food and hospitality, software and technology, telecommunications, sports and entertainment, banking and financial institutions, healthcare, and wholesale and retail. • Co-founded and managed various real estate acquisition, ownership, and operating entities, including commercial office buildings, shopping centers, flex warehouses, residential housing and developed land. • Performed tax and financial consulting services for individuals and closely held businesses. • Instructor in audit, accounting, finance, and forensic accounting. Part I: The Fraud * Page 56
  57. 57. BIOGRAPHY EDUCATION & CERTIFICATIONS • Bachelor of Science, Accounting – Mount St. Mary’s University • Certified Public Accountant (CPA)LAWRENCE J. HOFFMAN, • Certified Fraud Examiner (CFE)CPA/CFF, CVA, CFE • Certified in Financial Forensics (CFF) • Certified Valuation Analyst (CVA) • Private Investigator (PI), Virginia • Series 7 General Securities Representative (not active) • Series 24 General Securities Principal (not active) • Series 63 Uniform Securities Agent (not active) PROFESSIONAL ASSOCIATIONS & AFFILIATIONS • American Institute of Certified Public Accountants, Member • Virginia Society of Certified Public Accountants • Association of Certified Fraud ExaminersSENIOR PARTNER • National Association of Certified Valuation Analysts • Institute of Business Appraisers PERSONAL INTERESTS • Private pilot with instrument, multi-engine, high performance complex and aircraft ratings • Golf and fishing • Reading and politics Part I: The Fraud * Page 57

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