Surprise! SBAC and CRESST stonewall public records request for their financial records

Say what you will about Achieve, PARCC, Fordham, CCSSO, and NGA— some of the organizations responsible for promoting the Common Core Initiative on us all. But, their financial records are publicly available.

Not so for some other organizations responsible for the same Common Core promotion. The Smarter Balanced Assessment Consortium (SBAC) and the Center for Research on Educational Standards and Student Testing (CRESST) have absorbed many millions of taxpayer and foundation dollars over the years. But, their financial records have been hidden inside the vast, nebulous cocoon of the University of California – Los Angeles (UCLA). UCLA’s financial records, of course, are publicly available, but amounts there are aggregated at a level that subsumes thousands of separate, individual entities.

UCLA is a tax-supported state institution, however, and California has an open records law on the books. After some digging, I located the UCLA office responsible for records requests and wrote to them. Following is a summary of our correspondence to date:

 

July 5, 2017

Greetings:

I hope that you can help me. I have spent a considerable amount of time clicking around in search of financial reports for the Smarter Balanced Assessment Consortium (SBAC) and the National Center for Research on Evaluation, Standards, and Student Testing (CRESST), both “housed” at UCLA (or, until just recently in SBAC’s case). Even after many hours of web searching, I still have no clue as to where these data might be found.

Both organizations are largely publicly funded through federal grants. I would like to obtain revenue and expenditure detail on the order of what a citizen would expect to see in a nonprofit organization’s Form 990. I would be happy to search through a larger data base that contains relevant financial details for all of UCLA, so long as the details for SBAC and CRESST are contained within and separately labeled.

I would like annual records spanning the lifetimes of each organization: SBAC only goes back several years, but CRESST goes back to the 1980s (in its early years, it was called the Center for the Study of Evaluation).

Please tell me what I need to do next.

Thank you for your time and attention.

Best Wishes, Richard Phelps

 

July 6, 2017

RE: Acknowledgement of Public Records Request – PRR # 17-4854

Dear Mr. Phelps:

This letter is to acknowledge your request under the California Public Records Act (CPRA) dated July 5, 2017, herein enclosed. Information Practices (IP) is notifying the appropriate UCLA offices of your request and will identify, review, and release all responsive documents in accordance with relevant law and University policy.

Under the CPRA, Cal. Gov’t Code Section 6253(b), UCLA may charge for reproduction costs and/or programming services. If the cost is anticipated to be greater than $50.00 or the amount you authorized in your original request, we will contact you to confirm your continued interest in receiving the records and your agreement to pay the charges. Payment is due prior to the release of the records.

As required under Cal. Gov’t Code Section 6253, UCLA will respond to your request no later than the close of business on July 14, 2017. Please note, though, that Section 6253 only requires a public agency to make a determination within 10 days as to whether or not a request is seeking records that are publicly disclosable and, if so, to provide the estimated date that the records will be made available. There is no requirement for a public agency to actually supply the records within 10 days of receiving a request, unless the requested records are readily available. Still, UCLA prides itself on always providing all publicly disclosable records in as timely a manner as possible.

Should you have any questions, please contact me at (310) 794-8741 or via email at pahill@finance.ucla.edu and reference the PRR number found above in the subject line.

Sincerely,

Paula Hill

Assistant Manager, Information Practices

 

July 14, 2017

RE: Public Records Request – PRR # 17-4854

Dear Mr. Phelps:

The purpose of this letter is to confirm that UCLA Information Practices (IP) continues to work on your public records request dated July 5, 2017. As allowed pursuant to Cal. Gov’t Code Section 6253(c), we require additional time to respond to your request, due to the following circumstance(s):

The need to search for and collect the requested records from field facilities or other establishments that are separate from the office processing the request.

IP will respond to your request no later than the close of business on July 28, 2017 with an estimated date that responsive documents will be made available.

Should you have any questions, please contact me at (310) 794-8741 or via email at pahill@finance.ucla.edu and reference the PRR number found above in the subject line.

Sincerely,

Paula Hill

Assistant Manager, Information Practices

 

July 28, 2017

Dear Mr. Phelps,

Please know UCLA Information Practices continues to work on your public records request, attached for your reference. I will provide a further response regarding your request no later than August 18, 2017.

Should you have any questions, please contact me at (310) 794-8741 or via email and reference the PRR number found above in the subject line.

Kind regards,

Paula Hill

Assistant Manager

UCLA Information Practices

 

July 29, 2017

Thank you. RP

 

August 18, 2017

Re: Public Records Request – PRR # 17-4854

Dear Mr. Richard Phelps:

UCLA Information Practices (IP) continues to work on your public records request dated July 5, 2017. As required under Cal. Gov’t Code Section 6253, and as noted in our email communication with you on July 28, 2017, we are now able to provide you with the estimated date that responsive documents will be made available to you, which is September 29, 2017.

As the records are still being compiled and/or reviewed, we are not able at this time to provide you with any potential costs, so that information will be furnished in a subsequent communication as soon as it is known.

Should you have any questions, please contact me at (310) 794-8741 or via email at pahill@finance.ucla.edu and reference the PRR number found above in the subject line.

Sincerely,

Paula Hill

Assistant Manager, Information Practices

 

September 29, 2017

Dear Mr. Richard Phelps,

Unfortunately, we must revise the estimated availability date regarding your attached request as the requisite review has not yet been completed. We expect to provide a complete response by November 30, 2017. We apologize for the delay.

Should you have any questions, please contact our office at (310) 794-8741 or via email, and reference the PRR number found above in the subject line.

Best regards,

UCLA Information Practices

 

September 29, 2017

I believe that if you are leaving it up to CRESST and SBAC to voluntarily provide the information, they will not be ready Nov. 30 either. RP

Close all USED-funded research centers: Evaluation of existing regulations: My two bits

My comments below in response to the USED request for comments on existing USED regulations. To submit your own, follow the instructions at:  https://www.regulations.gov/document?D=ED-2017-OS-0074-0001

MEMORANDUM
To:  Hilary Malawer, Assistant General Counsel, Office of the General Counsel, U.S. Department of Education
From:  Richard P. Phelps
Date:  July 8, 2017
Re:  Evaluation of Existing Regulations[1]

Greetings:

I encourage the US Education Department to eliminate from any current and future funding education research centers. Ostensibly, federally funded education research centers fill a “need” for more research to guide public policy on important topics. But, the research centers are almost entirely unregulated, so they can do whatever they please. And, what they please is too often the promotion of their own careers and the suppression or denigration of competing ideas and evidence.

Federal funding of education research centers concentrates far too much power in too few hands. And, that power is nearly unassailable. One USED funded research center, the National Center for Research on Evaluation, Standards, and Student Testing (CRESST) blatantly and repeatedly misrepresented research I had conducted while at the U.S. Government Accountability Office (GAO) in favor of their own small studies on the same topic. I was even denied attendance at public meetings where my research was misrepresented. Promises to correct the record were made, but not kept.

When I appealed to the USED project manager, he replied that he had nothing to say about “editorial” matters. In other words, a federally funded education research center can write and say anything that pleases, or benefits, the individuals inside.

Capturing a federally funded research center contract tends to boost the professional provenance of the winners stratospherically. In the case of CRESST, the principals assumed control of the National Research Council’s Board on Testing and Assessment, where they behaved typically—citing themselves and those who agree with them, and ignoring, or demonizing, the majority of the research that contradicted their work and policy recommendations.

Further, CRESST principals now seem to have undue influence on the assessment research of the international agency, the Organisation for Economic Co-operation and Development (OECD), which, as if on cue, has published studies that promote the minority of the research sympathetic to CRESST doctrine while simply ignoring even the existence of the majority of the research that is not. The rot—the deliberate suppression of the majority of the relevant research–has spread worldwide, and the USED funded it.

In summary, the behavior of the several USED funded research centers I have followed over the years meet or exceed the following thresholds identified in the President’s Executive Order 13777:

(ii) Are outdated, unnecessary, or ineffective;

(iii) Impose costs that exceed benefits;

(iv) Create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies;

(v) Are inconsistent with the requirements of section 515 of the Treasury and General Government Appropriations Act, 2001 (44 U.S.C. 3516 note), or the guidance issued pursuant to that provision, in particular those regulations that rely in whole or in part on data, information, or methods that are not publicly available or that are insufficiently transparent to meet the standard for reproducibility.

Below, I cite only relevant documents that I wrote myself, so as not to implicate anyone else. As the research center principals gain power, fewer and fewer of their professional compatriots are willing to disagree with them. The more power they amass, the more difficult it becomes for contrary evidence and points of view, no matter how compelling or true, to even get a hearing.

References:

Phelps, R. P. (2015, July). The Gauntlet: Think tanks and federally funded centers misrepresent and suppress other education research. New Educational Foundations, 4. http://www.newfoundations.com/NEFpubs/NEF4Announce.html

Phelps, R. P. (2014, October). Review of Synergies for Better Learning: An International Perspective on Evaluation and Assessment (OECD, 2013), Assessment in Education: Principles, Policies, & Practices. doi:10.1080/0969594X.2014.921091 http://www.tandfonline.com/doi/full/10.1080/0969594X.2014.921091#.VTKEA2aKJz1

Phelps, R. P. (2013, February 12). What Happened at the OECD? Education News.

Phelps, R. P. (2013, January 28). OECD Encourages World to Adopt Failed US Ed Programs. Education News.

Phelps, R. P. (2013). The rot spreads worldwide: The OECD – Taken in and taking sides. New Educational Foundations, 2(1). Preview: http://www.newfoundations.com/NEFpubs/NEFv2Announce.html

Phelps, R. P. (2012, June). Dismissive reviews: Academe’s Memory Hole. Academic Questions, 25(2), pp. 228–241. doi:10.1007/s12129-012-9289-4 https://www.nas.org/articles/dismissive_reviews_academes_memory_hole

Phelps, R. P. (2012). The effect of testing on student achievement, 1910–2010. International Journal of Testing, 12(1), 21–43. http://www.tandfonline.com/doi/abs/10.1080/15305058.2011.602920

Phelps, R. P. (2010, July). The source of Lake Wobegon [updated]. Nonpartisan Education Review / Articles, 1(2). http://nonpartisaneducation.org/Review/Articles/v6n3.htm

Phelps, R. P. (2000, December). High stakes: Testing for tracking, promotion, and graduation, Book review, Educational and Psychological Measurement, 60(6), 992–999. http://richardphelps.net/HighStakesReview.pdf

Phelps, R. P. (1999, April). Education establishment bias? A look at the National Research Council’s critique of test utility studies. The Industrial-Organizational Psychologist, 36(4) 37–49. https://www.siop.org/TIP/backissues/Tipapr99/4Phelps.aspx

[1] In accordance with Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” the Department of Education (Department) is seeking input on regulations that may be appropriate for repeal, replacement, or modification.

“Organizationally orchestrated propaganda” at ETS

With the testing opt-out movement growing in popularity in 2016, Common Core’s profiteers began to worry. Lower participation enough and the entire enterprise could be threatened: with meaningless aggregate scores; compromised test statistics vital to quality control; and a strong signal that many citizens no longer believe the Common Core sales pitch.

The Educational Testing Service (ETS) was established decades ago by the Carnegie Foundation to serve as an apolitical research laboratory for psychometric work. For a while, ETS played that role well, producing some of the world’s highest-quality, most objective measurement research.

In fits and starts over the past quarter century, however, ETS has commercialized. At this point, there should be no doubt in anyone’s mind that ETS is a business–a business that relies on contracts and a business that aims to please those who can pay for its services.

Some would argue, with some justification, that ETS had no choice but to change with the times. Formerly guaranteed contracts were no longer guaranteed, and the organization needed either to pay its researchers or let them go.

Instead of now presenting itself honestly to the public as a commercial enterprise seeking profits, however, ETS continues to prominently display the trappings of a neutral research laboratory seeking truths. Top employees are awarded lofty academic titles and research “chairs”. Whether the awards derive from good research work or success in courting new business is open to question.

I perceive that ETS at least attempts something like an even split between valid research and faux-research pandering. The awarding of ETS’s most prestigious honor bestowed upon outsiders–the Angoff Award–for example, takes turns between psychometricians conducting high-quality, non-political technical work one year, and high-profile gatekeepers conducting highly suspicious research the next. Members of the latter group can be found participating in, or awarding, ETS commercial contracts.

With their “research” on the Common Core test opt-out movement, ETS blew away any credible pretense that it conducts objective research where its profits are threatened. Opt-out leaders are portrayed by ETS as simple-minded, misinformed, parents of poor students, …you name it. And, of course, they are protesting against “innovative, rigorous, high quality” tests they are too dumb to appreciate.

Common Core testing, in case you didn’t know and haven’t guessed from that written above, represents a substantial share of ETS’s work. Pearson holds the largest share of work for the PARCC exams, but ETS holds the second largest.

The most ethical way for ETS to have handled the issue of Common Core opt-outs would have been to say nothing. After all, it is, supposedly, a research laboratory of apolitical test developers. They are statistical experts at developing assessment instruments, not at citizen movements, education administration, or public behavior.

Choosing to disregard the most ethical choice, ETS could have at least made it abundantly clear that it retains a large self-interest in the success of PARCC testing.

Instead, ETS continues to wrap itself in its old research laboratory coat and condemns opt-out movement leaders and sympathizers as ignorant and ill-motivated. Never mind that the opt-out leaders receive not a dime for their efforts, and ETS’s celebrity researchers are remunerated abundantly for communicating the company line.

Four months ago, I responded to one of these ETS anti-opt-out propaganda pieces, written by Randy E. Bennett, the “Norman O. Frederiksen Chair in Assessment Innovation at Educational Testing Service.” It took a few weeks, but ETS, in the person of Mr. Bennett, responded to my comment questioning ETS’s objectivity in the matter.

He asserted, “There’s a lot less organizationally orchestrated propaganda, and a lot more academic freedom, here than you might think!”

To which I replied, “The many psychometricians working at ETS with a starkly different vision of what constitutes “high quality” in assessment are allowed to publish purely technical pieces. But, IMHO, the PR road show predominantly panders to power and profit. ETS’s former reputation for scholarly integrity took decades to accumulate. To my observation, it seems to be taking less time to dissemble. RP”

My return comment, however, was blocked. All comments have now been removed from the relevant ETS web page. All comments remain available to read at the Disqus comments manager site, though. The vertical orange bar next to the Nonpartisan Education logo is Disqus’ indication that the comment was blocked by ETS at its web site.

 

Martin Luther King’s non-violence: Personal belief or strategy or both?

On a day when we remember Martin Luther King, I want to share a personal perspective on his advocacy of non-violence. When the wisdom of a great person is invoked, omission of the context that gave it meaning demeans the person and distorts his/her message.

The origin of this reflection:

Shortly after 911, the teacher of the “Alternatives to Violence” class at Washington, DC’s Wilson HS, a DC Public School, invited a number of speakers opposed to the US military response to share their views with students and interested teachers.

Some also criticized the SAT as “racist,” “since poor black children shouldn’t be expected to know vocabulary words like ‘yacht’ they don’t hear at home.”*

Several spoke about the “AIDS conspiracy,” but were curiously silent about South African President Thabo Mbeki’s pseudo-scientific theories of its origins, the basis of his opposition to preventive health measures. No mention was made of the protests that Mbeki’s measures provoked.

One speaker, who had attended the recent UN World Conference Against Racism in Durban, South Africa, decried the fact that English was one of the conference’s eight “privileged” official languages. He was clearly oblivious to the fact that the Soweto uprising, which reignited the movement that culminated in the end of apartheid, began when Soweto high school students demanded the right to be taught in English, the language of Martin Luther King and Malcolm X, whose speeches on smuggled tapes were the target of the apartheid government’s thinly disguised censorship plan of making Afrikaans the language of instruction. (In 1979, when I was at Cardozo HS, with the backing of the Washington Teachers’ Union and its president, William Simons, I helped to organize a speaking tour of DC high schools for Soweto student leader Tsietsi Mashinini).

Speakers made frequent references to Martin Luther King Jr and his advocacy of non-violence, attempting to tie it to each of these issues. A few months later, on the occasion of his birthday, students and teachers were invited to a speak-out on non-violence and the war in Afghanistan (this was a year before the Iraq invasion). I gave the following talk.

– – – – – – – – – – –

MARTIN LUTHER KING’S NON-VIOLENCE:
PERSONAL BELIEF or STRATEGY or BOTH?

From a pay phone somewhere in the Negro neighborhood of Selma, Alabama, the scratchy sound of my friend Walter’s insistent voice stirred me. Following the Battle at Selma Bridge and the cowardly murder of Jim Reeb, the ex-minister of DC’s All Souls Unitarian Church, our safe classrooms overlooking the Potomac couldn’t keep him north. His picture had just appeared in Time Magazine, backed against a wall, dodging Sheriff Jim Clark’s trademark white cane, swung from horseback with punishing effect. I could think of no reason to stay away.

It was March 1965.
Two days later, my ’51 Merc was one of several carloads that ended up in Montgomery, Alabama, home of the Confederacy and George Wallace, its current symbol of defiance. We were among the many drawn to the last half dozen or so miles of that great and swelling march, where Martin Luther King, speaking on the capital steps, called upon the U.S. Congress to enact the stalled Voting Rights Bill. The marching, the singing and the exhilaration of a common bond of purpose forged indelible memories that gave life meaning and direction:

– Packed like sardines on the floor of Mr. Ziegler’s modern brick house on a dusty street in the “colored section” that the city fathers saw no need to pave;

– An old woman pressing a few hard earned dimes and nickels into my confused and hesitant hands, blessing me for coming to her city for a day that, for too long, lived only in hope and faith;

– Swaying to the low of “We Shall Overcome,” sung with a spiritual intensity that only long-awaited justice can evoke;

– The lasting images of the long line of marchers (my first of many) winding along the highway into Montgomery, especially noticeable for the religious diversity visible in religious garb: Priests and ministers wearing the Roman collar, nuns in their habits, men wearing the kippah (then more commonly called a yarmulke) and, as seen in the movie, a robed Eastern Orthodox prelate with cross and scepter, and the blue jean overalls favored by many of the young civil rights workers. Along the side of the road, again as in the movie, African-American children and older adults not joining in, but showing their support by smiling and waving at us.

– The prickly sensation of fear, when a jackbooted motorcycle cop, spotting my illegal left turn, pulled me over, New Jersey license plates, unimpeachable evidence of my sin as “outside agitator”:

“You boys comin’ from thuh ralllihh?”
“No, sir; we’re on our way back from Spring Break in New Orleans,”** were the timid words of discretion I heard myself speak.
“Youuu broke thuh law back a ways with that ill-legal left turn, an offense against thuh laws of Mon’gom’ry, Alibammuh. Youuu will folluh me to the cawthouse. Heahhh?”
“Yes, sir.”

With barely $20 between us, images of jail cells and the three recently murdered civil rights workers flashed through my mind.

I don’t really remember Martin Luther King’s speech; oh, something about voting rights and the governor’s refusal to protect the marchers. More meaningful than those forgotten words was his gift to me and countless others: A welcome into that great movement for justice and into the arms of humanity and the responsibilities that membership brings.

The power of that movement for justice and his accomplishments are misunderstood, if reduced to an oversimplified advocacy of non-violence. Understanding that it was simultaneously a strategy does not devalue his personal belief. From Thoreau’s writings on non-violent resistance to unjust laws to Gandhi’s practical application in India and the strategy workshops at Highlander Folk School (attended also by Rosa Parks), King’s vision was translated into Alabama reality by union veteran and NAACP leader E.D. Nixon. King’s vision and strategy were grounded on the confluence of evolving global changes and domestic realities that began with Brown vs. Board of Education in 1954, the irreparable fissure in America’s Berlin Wall of legalized segregation.

Like Gandhi, George Washington and even Ho Chi Minh, King understood that those who appeared to benefit from privilege were no monolith. The movement for justice could win support not only from those under the heel of Jim Crow but also from those on the other side of the color line, capable of rejecting a “just us” version of justice.
King also understood another reality that often discomforts those who favor social justice, but not when imposed by the Federal Government: Opponents often yield, not out of moral enlightenment, but when continued resistance seems futile. And, as long as resistance festers, it may reassert itself when it no longer seems futile.***

King understood the power of television. The brutal treatment of fellow Americans peacefully seeking to exercise constitutional rights long guaranteed on paper was witnessed daily in the nation’s living rooms and now became increasingly intolerable. The strategy of non-violence made nation and world witness to the real source of violence.

Then, too, the State Department had run out of red-faced explanations for the rude treatment and crude insults endured by African and Asian diplomats on Maryland’s Route 40 when driving between Washington embassies and UN offices in New York. As America competed with the Soviet Union for world leadership, the message of democracy and freedom increasingly stumbled on the hypocritical contrasts of those embarrassing facts.

Then there was that war in Viet Nam and Martin Luther King’s powerful sermon announcing his public opposition – and break with President Johnson, delivered at New York’s Riverside Cathedral on April 4th, 1967, a year to the day before violence born of hate stole his life.

But wait! Didn’t he receive the Nobel Peace Prize 3 years earlier – in 1964? And didn’t the U.S. troop escalation begin in March 1965, two full years before the Riverside sermon, by which time over 10,000 Americans and tens of thousands Vietnamese had been killed! Two years of public silence!! Where were the public condemnations from the apostle of non-violence? Was he a hypocrite? If so, why not just overlook that flaw whenever the sainted, now forever muted, icon of non-violence can be invoked for the final word!

For King, the commitment to civil rights and economic opportunity compelled him to choose between his personal revulsion against the violence of war and his reluctance to alienate the president who had signed two civil rights bills and funded a war on poverty – as well as that much bigger one in Vietnam. Was the resulting conflict between the non-violence of personal conviction and the strategy of non-violence that won political support against seemingly unmovable odds just another instance of the hypocrisy?

When his advocacy of non-violence is torn from the historical context that gave it life and then reduced to a rigid slogan or dogma, the lessons to be learned from the real human dilemma lose meaning and instructive value.

For that reason, we should treat with caution efforts to invoke his blessing on present-day [2002] controversies:

Would he have condemned the U.S. military response to 9/11?
Would he condemn the World Bank and International Monetary Fund?
Would he politely ignore South Africa President Thabo Mbeki’s pseudo-scientific AIDS fantasies?
Would he condemn SAT tests as racist?

Before rushing to offer a politically convenient answer, we should remember that, as a leader breaking new ground, he took responsibilities upon himself that made rigid adherence to doctrine or philosophy a luxury. Before invoking his blessing for some partisan cause, we should recall how easy it is to summon gods and icons to legitimize both human cruelty and human kindness.

Oh – some stories do end well. The fine for the moving violation on the streets of Montgomery: “City of Montgomery vs. Erich Martel: $3.00,” which, in 1965, was the price of 10 gallons of gas.

For Viola Liuzzo, however, a mother of five from Detroit who volunteered to drive marchers between Selma and Montgomery, a Klansman’s drive-by shotgun blast ended her life, joining her name to the countless many who paid the ultimate price in pursuit of justice.

— Erich Martel [originally written, January 15, 2002]

 

Notes:
* Core knowledge advocate E.D. Hirsch has pointed out that the 1960’s Black Panther Party newspaper employed correct grammar and used words like “imperialism,” “capitalism,” etc., assuming that its target audience would know or learn terms and concepts they were unlikely to hear at home.
** In fact, a mere 10 days earlier, a bunch of us had driven to New Orleans for Mardi Gras, which is probably why that came so quickly to mind.
*** We now see that this has come to pass. After the U.S. Supreme Court’s 2013 Shelby County decision weakened the enforcement provisions of the Voting Rights Act, many state legislatures began to enact restrictive voting laws.

Some Common Core Salespersons’ Salaries: DC Edu-Blob-ulants

Linked are copies of Form 990s for Marc Tucker’s National Center for Education and the Economy (NCEE), Checker Finn’s Fordham Foundation and Fordham Institute, and Bob Wise’s Alliance for Excellent Education (AEE). Each pays himself and at least one other well.

All non-profit organizations with revenues exceeding $50,000 must file Form 990s annually with the Internal Revenue Service. And, in return for the non-profits’ tax-exempt status, their Form 990s are publicly available.

As to salaries…

National Center for Education and the Economy
NCEE2013Form990 – Marc Tucker pays himself $501,087, and six others receive from $162k to $379k (p.40 of 48); his son, Joshua Tucker receives $214,813 (p. 42)
…also interesting: p.16 (contrast with p.15), pp. 19, 27, 37

Alliance for Excellent Education
AEE2013Form990 – Bob Wise pays himself $384,325, and six others receive from $162k to $227k. (see p.27 of 36)
…also interesting: p.24 (“Madoff Recovery”)

Thomas B. Fordham Foundation & Institute
FordhamF2013Form990 & FordhamI2013Form990 – With both a “Foundation” and an “Institute”, Checker Finn and Mike Petrilli can each pay themselves about $100k, twice. (see p.25 of 42)
…also interesting: p.19 ($29million in investments; $1.5million for an interest rate swap); p.37 (particularly the two entries for “Common Sense Offshore, Ltd.)