Specifically, records show that since 2009-2015, the club has made inappropriate and/or unexplained accounting entries or adjustments that have reduced shareable revenue in two ways: misclassifying sponsor, broker, and customer. Working with forensic accountants, the investigation identified, in the 2011-2015 seasons, approximately $9 million, which appears to have been protected by misclassification of shareable revenue held in accounts related to certain large sales to sponsors, brokers, and clients (“Sponsor, Broker, and Client Classifications”). A large portion, about $7 million, consists of revenue derived from NFL tickets sold or bartered with sponsors at bogus undervalued prices or revenue from amenities associated with NFL games that have been turned into special events. Contemporary emails discussing these revenues indicated a clear intent to falsify revenue records in order to avoid participation. For example, July 2010 communications revealed that the leaders decided the “least obvious” way to “avoid VTS impacts” on an NFL hospitality tent sold to a sponsor was to redirect the revenue ($17,773) to the hospitality tents for a Virginia Tech college game, even though “the transaction does not refer to VT” and they “will not [sic] Charge tickets for them.” When a staff member asked if it was “kosher” it was “redirection only[] The proceeds are not shareable [sic] Reply Section “A Senior Executive” [sic] a fine. “The other sponsor, broker, and customer misclassifications appear to have involved: (1) selling NFL tickets through brokers or on Internet ticket selling platforms and then classifying the resulting revenue as special event revenue; (2) reclassifying revenue from NFL tickets as non-sharingable revenue in hospitality accounts (for special events); and (3) recording forfeited security deposits on various NFL season tickets.” To improperly protect NFL revenue from participation, a forensic accounting audit was performed on certain transfers of revenue from NFL-related accounts to special event accounts. This review has identified, in the 2009-2015 seasons, an additional $44.49 million in ticketing, parking, licensing, and other revenue that the club originally recorded in an account identified as containing NFL-related proceeds appears to have been diverted into non-shareable special accounts.” In the absence of available accounting documentation to support the relevance of the vast majority of these transfers and apparent inconsistencies and weaknesses in the Club’s historical accounting practices, the investigation was unable to determine how much deferred income transfers represent legitimate non-shareable revenue or reflect incorrect revenue protection practices, including those identified in the sponsor, broker, and customer classifications. This has gone wrong for the following seasons: 2011 ($0.33 million); 2012 ($3.00 million); 2013 ($1.79 million); 2014 ($1.88 million); 2015 ($2.03 million). 16