Friday, March 16, 2018

Louisiana professor sentenced to 90 years in prison for misusing his state credit card: The shocking case of State v. Dorkmeister

Dr.  Dufus Dorkmeister, a folklore professor at the University of Louisiana at Lafayette, was sentenced to 90 years in prison last Friday for abusing his university credit card. Judge Shelly Dick sentenced Dorkmeister to 30 years in prison on each of three counts of fraud, with the sentences to be served consecutively. 

"This is one of the most serious cases of fraud and embezzlement I have ever seen," Judge Dick lectured  Dorkmeister before pronouncing sentence. "Therefore, in essence, I am sentencing you to life in prison. You will not be eligible for parole until you are 137 years old."

Dorkmeister was accused of three separate acts of fraud.  First, while traveling to an academic conference on 19th century Prussian folk life, he used his state credit card to buy an unauthorized donut in the New Orleans airport. According to the district attorney, the donut cost $1.82 (including sales tax).

 Dorkmeister testified it was a simple mistake. "My state card," he told the jury, " looks almost exactly like my personal credit care.  I just got the cards mixed up and  gave the cashier the wrong card."

Second, the District Attorney accused Dorkmeister of fraudulently seeking reimbursement for his parking fee at the New Orleans Airport.  State Policy requires all state employees to provide parking attendants with a signed form verifying they are on state business and should not be charged sales tax for parking fees.  Dorkmeister's fee was $7.70 cents, which included a 70 cent sales tax.

Again, Dorkmeister argued he was innocent. "I tried to give my official form to the parking attendant,' Dorkmeister testified tearfully, "but she laughed in my face and refused to deduct the 70 cents."

The third criminal charge, which the District Attorney described as the most serious offense, involved a purchase of 25 official University of Louisiana ballpoint pins without verifying that the pens were manufactured by a  vendor licensed to reproduce the University's logo. State policy requires professors to submit purchase requests for souvenir items to the Office of Communication and Technology, along with a photo of the vender's trademark license.

Dorkmeister testified at length on this matter. "I bought the ballpoint pens for my freshman students as little prizes for their academic work," Dorkmeister explained. "I did not know I had to get special permission from the Office of Communications and Technology to buy souvenirs bearing the University logo. I assumed the pens were legitimate because I bought them at the student union."

The District Attorney put Dorkmeister under savage cross-examination, forcing the professor to admit that ignorance of the law is no excuse. After deliberating for six minutes, the jury found Dorkmeister guilty on all three counts and recommended the maximum sentence.

After sentencing, Judge Dick denied bail while Dorkmeister appeals. The judge declared him a flight risk and remanded him for immediate deliver to Angola prison, where he will join 16 other professors. All 16 are housed in a maximum-security cell block  reserved for rapists, child molesters and credit-card abusers.

College professors convicted of credit card abuse.

Universities Are Mired In Paperwork: The Battle of Isandlwana revisited

On January 22, 1879, thousands of Zulu warriors attacked a strong and well-armed British force camped on the slopes of Mount Isandlwana and virtually wiped it out.

It is true the British unit was badly outnumbered: 20,000 Zulus against 1,800 British soldiers.  But the British were well armed with modern Martini-Henry rifles, two cannons, a rocket battery, and half a million rounds of ammunition.

Had the British deployed their forces competently, the army would have survived. Later on the same day a much smaller detachment of only 140 British soldiers staved off a Zulu attack at Rorke's Drift although outnumbered by more than 20 to 1.

But Lt.-Col. Henry Pulleine,  commander at Isandlwana, failed to grasp his peril until it was too late. He was slow to realize the size of the Zulu army, and he placed his men in a skirmish line far from the main camp's munitions. The ammunition boxes themselves were screwed shut and required a special screwdriver to open. The quartermasters in charge of distributing the bullets refused to give them out except to men from their own units.

In a word, the people in charge at Isandlwana were not problem solvers. In the end, about 1,200 British soldiers were slaughtered; only men on horseback survived the day.

I'm a lowly professor not likely to be speared by a Zulu, but I sometimes think of the battle of Isandlwana, because in fact, universities often act like Commander Pulleine and make things far more difficult for professors than they need to be.

When I worked at the University of North Texas, I drove my own car to teach courses off campus at sites all over the Dallas-Fort Worth metropolitan area. At the end of each semester, I filled out a log sheet recording all my official travel so I could get reimbursed for my expenses. I listed each site I visited, and a secretary independently verified how many miles I drove to get to a particular teaching destination. Filling out the log book took me ten minutes, and I received my reimbursement check in about ten days.

Today, I work at the University of Louisiana at Lafayette, and I teach some of my courses in other towns. One semester, I taught in Alexandria, which is 80 miles from Lafayette. Although I drove my own car to teach a course 80 miles from my office, state policy only allows me to be reimbursed for traveling 50 miles.  If I want the university to fully cover my travel costs, I am required to rent a car from Enterprise.

Instead of filing out a log sheet to get reimbursed, as I did at UNT, I am required fill out a travel request for each trip.  I drove to Alexandria ten times one semester and I filled out ten forms (each in triplicate). Each time I filled out the form I listed my personal insurance policy number and driver's license number and verified that I had taken the University's driver-safety course.

After that semester, I decided to bear my own travel costs. Renting a car from Enterprise, which the University apparently wanted me to do, just doesn't work for me. By the time I got back from Alexandria at 9:30 at night, Enterprise was closed. The time spent filling out ten forms only to get partially reimbursed wasn't worth the measly reimbursement checks I received.

Now all professors at Louisiana public universities are required to obtain university credit cards for all our expenses--cards issued by Bank of America. All air travel must be booked through Short's Travel, a private travel agency based in Iowa.

What if I can find a cheaper  flight through Travelocity or Expedia? Under the official rules, I can book the cheaper fare if  the flight is at least $50 less expensive and I have written verification from Short's Travel that it can't match the price.

My university is based in Lafayette, Louisiana, which has a regional airport. It is always cheaper to fly out of Baton Rouge or New Orleans, but a professor can't do that unless Short's Travel provides written verification that in fact a ticket out of Baton Rouge costs less than a ticket out of Lafayette.

If I attend an out-of-state professional conference, will the university reimburse me for my food? Yes, it will; but only if I provide a copy of the official conference program proving that my registration fee doesn't include any meals.

Can I get reimbursed when I pay for parking at the airport parking garage? Certainly, but I must present the parking attendant with a signed form attesting that I am on state business and must not be charged sales tax.

And all travel must be signed off on by the following people: My department chair, my dean, an "administrative head" (don't know who that is), the Director of Administrative Services, the Assistant Vice President for Financial Services, and the Vice President of Administration and Finance.

How long does it take to gather all these signatures? About 30 days.

And I when I return from my conference, I must turn in all my receipts and these receipts must be originals. All my receipts are then digitally archived as evidence in case the District Attorney decides to prosecute me some day for abusing my credit card. I'm told there is a professor doing 30 years in Angola Prison for buying an unauthorized donut at the Medieval Scholars Association's annual meeting in Kansas City.

So sometimes I feel as if I am a soldier in Her Britannic Majesty's army, posted on the slopes of Mount Isandlwana, trying to hold off the Zulus as I run out of ammunition. But I am not treated like a soldier in Her Majesty's army. The State of Louisiana seems to think I am a criminal.

If only I had my official I.D. card, I could get some more bullets.

Monday, March 12, 2018

Fed Chairman Jerome Powell says he can't explain why student loans can't be discharged in bankruptcy: An astonishing admission that the emperor wears no clothes

Federal Reserve Chairman Jerome Powell made an astonishing admission at a Senate Banking Committee hearing last month.  He said he could not explain why federal law does not allow distressed debtors to discharge their student loans in bankruptcy.

"I think alone among all kinds of debt, we don’t allow student loan debt to be discharged in bankruptcy," Powell said. "I'd be at a loss to explain why that should be the case."

Powell also acknowledged that mounting student indebtedness could injure the American economy. "It’s not something you can pick up in the data right now," Powell told the Banking Committee, "but at this goes on, and as student [debt] gets larger and larger, it absolutely could hold back growth." 

Fed Chairman Powell is not the first senior Washington official to admit that the student loan program could hurt the American economy. Former Fed Chair Janet Yellen made a similar observation in 2014. "The [student] debt loads certainly are high enough that they may play a role in, for example, making it hard for people to buy first homes, to build a down payment,” Yellen said at a hearing of the Senate Budget Committee.  

But Powell's remarks last month is the first time a senior federal official has candidly admitted that he cannot explain why the Federal Bankruptcy Code makes it very difficult for overburdened college debtors to discharge their student loans through bankruptcy.

In essence, Chairman Powell's surprisingly candid remark is very much like the children's story about the emperor who wore no clothes. Everyone knew the emperor wasn't wearing clothes, but no one was brave enough to state the obvious until a child explained: "The emperor is naked!"

I think Chairman Powell's frank observation may be just the nudge our government needs to honestly address the fact that millions of Americans who took out student loans in good faith simply can't pay them back.

How can the Chairman's remarks be exploited?

I. Alert the bankruptcy judges to the Fed Chair's remarks

First, all student debtors who attempt to their discharge student loans in bankruptcy should notify the bankruptcy judge--either in the complaint itself or in a pleading--that a top economic official in the federal government cannot explain why honest student debtors are barred from shedding their burdensome student loans through bankruptcy.

Powell's observation stands in stark contradiction to the stance taken by the Department of Education and the student-loan debt collectors that have fought bankruptcy relief for almost all student debtors.  For example, DOE opposed bankruptcy relief for a quadriplegic debtor in the Myhre case, and Educational Credit Management Corporation (ECMC) fought Janet Roth, an elderly woman in poor health who was living on less than $800 a month, all the way to the Ninth Circuit Bankruptcy Appellate Panel.

How can DOE and ECMC defend their heartless behavior when the Chair of the Federal Reserve says he can't explain why our government puts onerous restrictions on bankruptcy relief  for insolvent student debtors? Powell's remark might be just the piece of evidence bankruptcy courts need to begin discharging student loans in bankruptcy under more humane standards than currently prevail.

II. Powell's statement should spur a bipartisan effort in Congress to amend the Bankruptcy Code

Second, Powell's admission should prompt Republicans and Democrats to join in a bipartisan push to amend the Bankruptcy Code to remove the "undue hardship" provision in 11 U.S.C. sec. 523 (a)(8). Representatives Katko and Delaney have filed a bill to remove the "undue hardship" clause from the Bankruptcy Code, but so far the bill has gone nowhere.  Senators Warren and McCaskill have introduced a bill to stop the federal government from garnishing Social Security payments to insolvent, elderly student debtors, but that bill too has gone nowhere.

Surely Powell's statement should be all the encouragement Republicans and Democrats need to revise the Bankruptcy Code so that student loans are dischargeable in bankruptcy like any other consumer debt.

Fed Reserve Chair Jerome Powell


Joseph Lawler. Federal Reserve chairman: Mounting student debt could hold back economic growth. Washington Examiner, March 1, 2018.

Joseph Lawler. Janet Yellen warns student debt may be holding back housing recovery. Washington Examiner, May 8, 2014.

Representative John Delaney press release. Delaney and Katko File Legislation to Help Americans Struggling with Student Loan Debt. May 5, 2017.

Wednesday, March 7, 2018

Alexander Holmes v. National Collegiate Student Loan Trust: Don't co-sign your children's student loans!

In 2006, Alexander Holmes co-signed a student loan with Charter Bank One to fund his son's education at the University of Southern Indiana. Charter Bank sold Holmes' loan in a pool of loans to National Collegiate Funding, which then sold the loan to National Collegiate Student Loan Trust (NCSLT).

Ten years later, NCSLT sued Mr. Holmes, claiming he owed more than $16,000 on the loan plus accrued interest. Holmes denied NCSLT's claim and argued that NCSLT did not have standing to sue him.

NCSLT moved for summary judgment, which an Indiana trial court granted. The court then ordered Holmes to pay NCSLT $18,183.26 plus interest and costs.

But Mr. Holmes had a good lawyer and he appealed. An Indiana appellate court reversed the lower court's order against Mr. Holmes on the grounds that NCSLT had not provided admissible evidence that it had the right to collect on the debt Holmes owed Charter Bank.

The court's reasoning is a bit technical; but this is a summary of the appellate court's decision:
In support of its motion for summary judgment against Mr. Holmes, NCSLT offered the affidavit of Jacqueline Jefferis, an employee of Transworld Systems, Inc. (TSI), which was the "loan subservicer" for U.S. Bank, National Association, which the court identified as the "Special Servicer" working for NCSLT.

In a sworn statement, Ms. Jefferis' said she was familiar with TSI's business practices regarding loan records. But, as the Indiana Court of Appeals pointed out:

[T]he Jefferis affidavit provided no testimony to support the admission of the contract between Holmes and Charter One Bank or the schedule of pooled loans sold and assigned to National Collegiate Funding, LLC, and then to NCSLT . . . . There was no testimony to indicate that Jefferis was familiar with or had knowledge of the regular business practices or record keeping of Charter One Bank, the loan originator, or that of NCSLT regarding the transfer of pooled loans . . . . [Emphasis added by me.
In other words, as far as the appellate court was concerned, Ms. Jefferis didn't know nuthin' about no loan from Charter Bank to Mr. Holmes. Consequently, the trial court's judgment against Mr. Holmes was reversed.

Why is the Holmes case, decided by an Indiana state court, important to other student-loan debtors? Three reasons:

I. The private student-loan industry is bundling student loans and selling them to investors

First, the private student-loan industry has been packaging student loans into bundles (or pools) and selling them to third parties, and these third parties often then sell these bundled loans to yet other parties. In fact, these loans can have multiple owners.

In this flurry of transactions, the paperwork often gets mislaid or lost. Sometimes the companies suing student-loan debtors for payment do not have the critical documents necessary to show that they have the legal right to collect on the debt.

This confusion sometimes occurs due to "robo-signing," the mindless signing of documents by people who are not familiar with the original transactions. This was a significant issue during the home-mortgage crisis of 2008, and judges sometimes dismissed home-foreclosure suits because the parties trying to foreclose on houses could not prove they were entitled to grab someone's home.

Thus, anyone who is sued by a company trying to collect on a private student loan should demand that the suing party show that it is the legal entity entitled to sue for the money. Fortunately for Mr. Holmes, NCSLT was unable to show that it was the party that had legal standing to sue him.

II. Student-loan debtors need good lawyers

This brings me to the second reason the Holmes case is significant for other student-loan debtors. Mr. Holmes defeated NCSLT on a technicality. Specifically, NCSLT's documentation did not pass muster with Indiana Evidence Rule 803(6). But only a competent lawyer would know how to make the technical argument that benefited Mr. Holmes.

I once thought that student-loan debtors with the right facts could go into court without lawyers and be successful. And indeed, some debtors have won their cases in federal bankruptcy courts over the ruthless opposition of the debt collectors' lawyers.

But many of these cases turn on legal technicalities that a nonlawyer could not be expected to know. The Holmes case was based on Indiana law, but federal bankruptcy law also has technicalities that nonlawyers will find very difficult to master.

That is why I was heartened by the decision of the Massachusetts Bar Association to organize teams of volunteer lawyers to represent student-loan debtors in bankruptcy courts. If student-loan debtors can get good lawyers, they will have a far better chance of winning their cases than if they go to court without legal counsel.

III. Never co-sign your children's student loans

There's a third lesson to be learned from the Holmes case. Mr. Holmes co-signed a student loan with his son Nicholas to enable Nicholas to enroll at the University of Southern Indiana. In my view, that was a mistake. If Nicholas couldn't figure out a way to attend a regional state university without having his dad co-sign a student loan, then Nicholas needed to figure out another way to go to college.

I've said this before, and I'll say it one more time. Parents should never co-sign their children's student loans. Never. Never. Never.

Note: My thanks to Steve Rhode for calling my attention to Holmes v. 


Alexander Holmes v. National Collegiate Student Loan Trust (Ind. Ct. App. Feb. 27, 2018).

Steve Rhode. Perfect Example Why Most National College Student Loan Trust Lawsuits are BS. Getoutofdebtguyorg., March 1, 2018.

Thursday, March 1, 2018

Lady Bird, the movie, sends an insidious message about elite East Coast colleges (Spoiler Alert)

Lady Bird, Greta Gerwig's  new coming-of-age movie, has been nominated for five Academy Awards, including Best Picture. But it is an insidious movie, which delivers a treacherous message that self-fulfillment can be found at an elite East Coast college.

Christine, who calls herself Lady Bird, is a discontented California girl who attends a Catholic high school in Sacramento. Her mother doesn't understand her, the guy she is sweet on is gay, and she cheats on her exams.

To make matters worse, Lady Bird's parents live in a tiny ranch-style home, with only one bathroom. She self-deprecatingly tells her boyfriend she lives on the wrong side of the tracks, an insult he guilelessly passes on to her mom and dad.

Sacramento bores Lady Bird, which she dismisses as "the Midwest of California." She longs to escape California to go to college on the East Coast.   Although several elite schools reject her, she finally get accepted to a fancy college in New York.

But the school is expensive. Her father, who comes across as a genuinely nice guy, recently lost his job; and at his age, he is unlikely to get another one. Lady Bird's mother, a nurse, works double shifts at a hospital to make ends meet.

But Lady Bird simply must go east to college, so her dad refinances the family home to cover the cost. The movie ends with Lady Bird in New York City, where she lies to one of the first guys she meets and tells him she is from San Francisco.

What a piece of crap! Any young woman who allows her out-of-work father to refinance the family's pathetic little house so she can attend a snooty East Coast college is a self-absorbed jerk. Although the movie is pitched as a young woman's heroic quest for self-fulfillment, it's really just a gratuitous insult to flyover country, which the filmmaker expanded to include parts of California.

Friday, February 16, 2018

Congress enacts teeny weeny student-loan reform legislation: Is the glass half full or half empty?

As reported by Steve Rhode, Congress passed a very modest student-loan reform bill late last year.  Titled the Stop Taxing Death and Disability Act, the new law eliminates an unfair tax on forgiven student loans.

Prior to passage of this law, the government would forgive student loans held by debtors who became permanently disabled, but the amount of the forgiven debt was considered taxable income by the IRS. You may remember the story of Will Milzarski,  a military veteran who was wounded and disabled while fighting in Afghanistan.  The Department of Education forgave about a quarter of a million dollars in student loans, but the IRS sent Mr. Milzarski a tax bill for $62,000.

The Stop Taxing Death and Disability Act, which was adopted by Congress with bipartisan support, eliminates this unfair tax provision. Under the new law, all student-loan debt (including private student loans) that is forgiven due to the death or disability of the debtor is exempt from federal income taxes.

In addition, the law gives a tax break to the parents of student-loan debtors. Parents who owe student loans on behalf of their children may obtain a student-loan discharge if their child becomes disabled.  And parents who obtain such a discharge won't be taxed on the forgiven debt.

So, is the glass half full or half empty?

On the good side, passage of this modest and noncontroversial bill is a sign that Republicans and Democrats can work together to pass student-loan reform legislation. The bill's three co-sponsors--Senators Rob Portman (R-Ohio), Chris Coons (D-Delaware), and Angus King (I-Maine) are to be commended for getting this little bill adopted.

But on the other hand, as Mr. Rhode pointed out, the bill did not address the enormous tax liability that college borrowers face who are in income-driven repayment plans (IDRs).  More than six million student debtors are enrolled in IDRs, and most of them are making monthly loan payments so small that they will never pay off their loans.  Why? Because the monthly payments aren't large enough to cover accruing interest on the underlying debt.

People locked into IDRs are obligated to make monthly loan payments for terms that stretch out for 20, 25 and even 30 years. At the end of the repayment term, any remaining unpaid debt is forgiven, but the amount of the forgiven debt is considered taxable income.

In other words, a student debtor who successfully completes a 20-year IDR sheds one unpayable debt to the Department of Education and acquires another unpayable debt to the IRS.

Nevertheless, the fact that Congress passed the Stop Taxing Death and Disability Act is a good sign. Maybe Democrats and Republicans can build on this tiny victory to enact more sweeping student-loan reform.

For example, perhaps a bipartisan coalition could rally behind the Warren-McCaskill bill to stop the IRS from garnishing the Social Security checks of elderly student-loan defaulters. Who in good conscience could vote against that bill?

And is it too much to hope that Congress might someday reform the Bankruptcy Code and allow suffering student-loan borrowers to discharge their crushing student loans in bankruptcy?

Will Milzarski, Wounded Veteran (photo credit: Chicago Tribune)


Associated Press. Wounded Michigan vet gets student loan debt forgiven, but now IRS wants $62,000Chicago Tribune, October 20, 2017.

Judith Putnam. Student debt forgiven, but wounded vet gets $62,000 tax billUSA Today, October 20, 2017.

Representative John Delaney press releaseDelaney and Katko File Legislation to Help Americans Struggling with Student Loan Debt, May 5, 2017.

Representative John Katko press release. Reps. Katko and Delaney File Legislation to Help Americans Struggling with Student Loan Debt. May 8, 2017.

Steve Rhode. 15 Seconds of Positive News About Student Loans and Congress. Get Out of Debt Guy, February 15, 2108.

Tuesday, February 13, 2018

For the sake of the economy, let's forgive all student-loan debt

Forty-four million people are burdened by student loans--totally about $1.5 trillion in outstanding debt. What would happen if the federal government just forgave all those loans?

Researchers at the Levy Economics Institute of Bard College asked that question, and their answer might surprise you. Forgiving all this debt, they say, would boost the Gross National Product by $86 billion to $108 billion a year over a ten-year period. Released from their student loans, millions of people would see an immediate increase in their disposable income, permitting them to buy homes, save for retirement, purchase consumer goods, and start families.

Moreover, as Eric Levitz pointed out, Congress passed a $1.5 trillion tax cut last year, with most of the benefits going to the wealthy. Wouldn't it have made more sense to have forgiven $1.5 trillion in college loans instead? Most of the benefits would have gone to low-income and middle income Americans--not the rich.

Of course, our government can't simply forgive $1.5 trillion in student loans and continue the federal student loan program. The thing to do, then, is to replace the student-loan program with free undergraduate education at a public college or university.

But wouldn't that be prohibitively expensive? No it wouldn't. As Ryan Cooper argues, the total cost of tuition at public institutions was only $58 billion in 2014.  Our government invests twice that amount each year in the federal student loan program. It would actually be less expensive to American taxpayers if we simply shut down the student loan program and gave everyone a free college education at a public college.

Theoretically, it is true, the federal government is only loaning students money to attend college; it expects to get that money back at interest as students pay off their student loans. But in fact, about half of the nation's outstanding student-loan balance will never be paid back. It's just going down a rat hole for educational experiences that are overpriced and that often don't lead to well-paying jobs.

Of course, forgiving everyone's student loans and providing a free college education would have some major collateral consequences. If Americans could get a free college education at a public institution, they would stop enrolling in private colleges and for-profit schools.  If the federal government actually implemented this plan, small liberal arts institutions all over the United States would close their doors and the for-profit college industry would collapse.

But the private liberal arts colleges will be closing anyway. Harvard professor Clay Christensen predicts that half of them will close within the next 10 to 15 years as Americans figure out that it makes no sense at all to spend $200,000 to get a liberal arts degree from a nondescript college in the upper Midwest.  As for the for-profit schools, they are a cancer and should be closed down anyway.

But, critics might ask, what about the moral hazard of forgiving all that debt? Is it fair to allow people to borrow $100,000 or more to get an MBA and then not pay it back?

First of all, the student borrowers who are suffering the most have been people who borrowed a relatively small amount of money. People who have borrowed the least are most likely to default. It is true that some people whose student loans are forgiven would receive a windfall, but the vast majority of people who would benefit from wholesale student-loan forgiveness would be people who paid too much money for postsecondary education and did not get fair value.

Furthermore, whatever moral taint can be found in student-loan forgiveness is as nothing compared to fraud committed by the for-profit college industry, the exploitation by the student-loan debt collectors, and the venality of university presidents making million-dollar salaries while students are forced to borrow more and more money to pay escalating tuition rates.

And if massive student-loan forgiveness still sticks in the nation's craw, then let's just reform the bankruptcy laws and allow deserving debtors to obtain relief from their student loans in the bankruptcy courts. If the "undue hardship" provision were removed from the Bankruptcy Code, literally millions of Americans would file bankruptcy and get relief.

But the Bard College researchers have gotten to the heart of the matter. We should forgive all student loans and simply allow people to study for free to get an undergraduate education at a public university.


Ryan Cooper. The case for erasing every last penny of student debt. The Week, February 8, 2018.

Doug Lederman. Clay Christensen, Doubling Down. Inside Higher Ed, April 28, 2017.

Eric Levitz. We Must Cancel Everyone's Student Debt, for the Economy's Sake. New York, February 9, 2018.

Scott Fullwiler, Stephanie Kelton, Catherine Ruetschlin, and Marshall Steinbaum. The Macroeconomic Effects of Student Debt Cancellation. Levy Economics Institute of Bard College, February 2018.