A Report Produced by New York Citizens Audit

The findings in this report are based upon the three basic tenets of an election:
1 Voter rolls must be accurate,
2 Votes counted must be from qualified electors,
3 The number of votes must equal the number of voters who voted.

As well as the following principles in federal law:
1 Every point of administration of a federal election must create an auditable record1;
2 These records can be used to validate the accuracy of election results2;
3 The maximum allowable error rate in a valid, trusted election is 1/125,000 ballots in error3.

Our US Congress recognized in 1993 that in order to secure government by consent, the principle of American liberty and justice upon which our constitutional republic was founded, the electoral process must be protected by maintain- ing accurate voter rolls:
52 USC 20501 (National Voter Registration Act of 1993.) SEC. 2. FINDINGS AND PURPOSES.
(a) FINDINGS—The Congress finds that—
(1) the right of citizens of the United States to vote is a fundamental right;
(b) PURPOSES—The purposes of this Act are—
(3) to protect the integrity of the electoral process; and
(4) to ensure that accurate and current voter registration rolls are maintained.

Congress was right. A voter registration record is granted a ballot. Eligibility must be verified before any applicant can be registered. Maintenance of registration lists must be scrupulous. If a name appears on the list of registered voters, it is presumed to be legitimate, and allowed to cast a vote.

Through inspection of the voter rolls4 in New York State, NY Citizens Audit has discovered they are so inaccurate, the circumstance is described under the law as a total “Loss of Control.”5 Federal and state laws regarding registration are simply ignored. Millions of examples exist. Regardless of blanket excuses and denials from election officials, these are invalid or illegal registrations. Crimes against the elective franchise are being committed.

Here is a sampling of registration records from the New York State voter roll database (NYSVoter) as of December 19, 2022 that are invalid or illegal. Some of them could be given an affidavit ballot to vote at an in-person polling site under state law, if a proper cure is presented. Although their presence in the database violates the federal principle of accuracy due to ineligibility, current state law excuses that.

Counterfeit registrations (see page 3) 1,467,399
Registered after 2022 GE cutoff date, yet voted 9,766
Purged with no purge date 1,545,711
Purged records that were never active (see page 5) 712,360
Registered after last voted date 143,226
Voter identity unverified 201,908
Age discrepant registrants (older than the 115yo, the oldest known person in the US) 20,023
Registered before age 16 4,910
Blank address registrants 48,784
January 1st registration date, 1900-2022 988,863

Counterfeit registrations are made using a pre-existing registration identity as the source, but assigning the new record a unique statewide voting serial number. This creates the opportunity for multiple votes to be cast by the same identity. In some cases the original registration is real and verifiable by direct canvass. In other cases the original is unverifiable by direct canvass or other means; the “voter” is fictitious.


52 USC 21083 (Help America Vote Act of 2002)
SEC. 303. Computerized statewide voter registration list requirements and requirements for voters who register by mail.
(a) computerized statewide voter registration list requirements
(1) Implementation
(A) in general—Except as provided in subparagraph (B), each State, acting through the chief State election official, shall implement, in a uniform and nondiscriminatory manner, a single, uniform, official, centralized, interactive computerized statewide voter registration list defined, maintained, and administered at the State level that contains the name and registration information of every legally registered voter in the State and assigns a unique identifier to each legally registered voter in the State.

52 USC 20504 (National Voter Registration Act of 1993.)
SEC. 5. Simultaneous application for voter registration and application for motor vehicle driver’s license.
(c) forms and procedures.
(2) The voter registration application portion of an application for a State motor vehicle driver’s license—
(B) may require only the minimum amount of information necessary to—
(i) prevent duplicate voter registrations.

NYS Election Law §5-614.4
There shall be one official record of the registration of each voter. Such record shall be maintained in an interactive, statewide, computerized, voter registration list. Such statewide voter registration list shall constitute the official list of voters for the state of New York.
NYCRR 6217.1
(b) NYSVoter shall maintain one record for each voter including the statewide unique identifier.
NYCRR 6217.5
(e) NYSVoter shall assign a unique identifier to every voter that will remain with that voter for their voting life.

New York State board of elections excuses 1,467,399 counterfeit registrations
In an official document targeting the efforts of NY Citizens Audit, “False Claims Explained,”6 The New York State board of elections (NYSBOE) implies that these federal and state laws are not actually law. An excuse is given to dismiss concerns about the board’s flagrant disregard of election law. The lack of audit records demonstrating the veracity of the excuse is notable, given it is part of an election official’s sworn, affirmative duty to provide evidence proving their work meets the legal standard. The excuse does not address cases like A. Piamenta, an unverifiable “person” who has eleven simultaneously active registrations at a single address where he is unknown and has never lived. In short, the excuse is false. Below is the excuse as provided by the NYSBOE in “False Claims Explained”:

Duplicated Voter IDs
Each voter in New York is assigned both a state voter ID and a county ID. Although the state database is designed to have a single state ID follow a voter as they move from county to county, it is possible for multiple reasons that a voter may have multiple records with different state IDs. For example, if a voter registered more than once using the DMV’s online portal creating a duplicate record, their duplicate record may be purged, which would show the same voter and name with two voter IDs. One record would be active and the second would be purged.

When NY Citizens Audit researchers searched the NYSVoter database as provided on December 19, 2022, we found 1,467,399 counterfeit registrations assigned to identities already granted a voter registration and unique statewide identifier. To find out if they voted, please turn to page 7, “Votes counted must be from qualified electors.”

In the official DOJ publication, “Federal Prosecution of Election Offenses, Eighth Edition, December 2017,” the following federal crimes are identified:
• Submitting fictitious names to election officers for inclusion on voter registration rolls, thereby qualifying the ostensible voters to vote in federal elections (52 U.S.C. §§ 10307(c), 20511(2)).
• Providing false information concerning a person’s name, address, or period of residence in a voting district to establish that person’s eligibility to register or to vote in a federal election (52 U.S.C. §§ 10307(c), 20511(2)).
• Placing fictitious names on the voter rolls. This “deadwood” allows for fraudulent ballots, which can be used to stuff the ballot box.

The law identifies each of these 1,467,399 counterfeit registrations as both illegal and suspicious. The New York State board of elections must provide a line-by-line verification detailing how each one of them was created, as well as the computer audit logs demonstrating every update to voter history. These records have been requested by NY Citizens Audit via Freedom of Information Law (FOIL), and access has unlawfully been denied.

NY Citizens Audit discovered 712,360 voter registration records in NYSVoter that were never active.
At the time each record was created, it was given purged status. This is a conundrum, as a purged voter cannot get a ballot under any circumstance. Why, then, did these “people” register?

These 712,360 records appear to be fraudulent. How they may have been used, exactly, remains unknown. Again, the New York State board of elections must provide a line-by-line verification detailing how each one of them was created, as well as the computer audit logs demonstrating every update to voter history.

NY Citizens Audit used three uniquely dated copies of NYSVoter to run a comparison, line-by-line, of anomalous changes to the database. One copy is dated 10/21/2021, the second 10/24/2022, and the third was received on 12/19/2022. The results are inexplicable and possibly illegal:

Categories of Inexplicable Changes to the Voter Rolls Number of Changes October 2021 –
October 2022 Number of Changes October 2022 –
December 2022 Total Changes
over 14 months
Purged became inactive 6,586 3 6,589
Purged became active 45,260 274 45,534
Died became active 25 50 75
Purge date moved back in time 11 6 17
Purge date moved ahead in time 1,216 122 1,338
Purge date erased 7,171 229 7,400
Purged no purge date 56,772 36,627 93,399
Birth date moved back in time 3,226 835 4,061
Birth date moved ahead in time 3,672 927 4,599
First name altered 14,604 3,760 18,364
Last name altered* 12,502 3,267 15,769
New ID, same name 10,808 2,931 13,739
New Lname/Fname/DOB, same ID 65 20 85
New Lname/ID, same Fname/DOB 235 39 274
New Lname/DOB, same Fname/ID 256 72 328

*Married name changes not included

Each one of these changes would need to be manually done, based on a legitimate request by the voter, at the local board of elections where the voter resides. This would be an average of 680 illogical registration changes per business day, statewide. The boards of elections must produce every one of these record update requests, submitted by each unique registrant, in order for this finding to be believed lawful.

In the spring of 2022, NY Citizens Audit Director of Research, Andrew Paquette, PhD, observed and began reverse- engineering algorithmic patterns in the assignment of state and county voter ID numbers within NYSVoter.

On June 27, 2022, with the support of the team, this work was reported in person to the New York State Police Special Investigations Unit. The report was considered credible and disturbing, and the inquiry passed to the Foreign Intelligence Task Force of the FBI, which oversees investigation of national security risks to our voting systems.

On May 1, 2023, NY Citizens Audit presented the completed research on these algorithms to the New York State legislature election committees, at the Legislative Office Building in Albany, room 711A.7

On May 16, 2023, Paquette published a peer-reviewed scientific research paper, “The Caesar Cipher and Stacking the Deck in New York State Voter Rolls,” describing the algorithms, in the Journal of Information Warfare8. Three independent cyber-intelligence experts agreed that the research was sound, and the database is embedded with steganographically masked (hidden in plain sight) algorithms controlling the assignment of ID numbers.

This is blatantly illegal, and considered a total “Loss of Control” data breach by the Cybersecurity and Infrastructure Security Agency, the federal agency with the duty to protect critical national cyber infrastructure. Neither the FBI, nor the legislators, nor any other officials have responded, despite having been presented credible evidence of an existing national security breach within our voting system. It is misconduct to ignore the report; each of these people swore an oath to protect and uphold our US Constitution.

The breach may explain some of the massive data manipulation discovered by NY Citizens Audit. There is a possibility that the manipulation has been accomplished without knowledge of or participation by any New York election official. However, the state board of election’s choice to defend millions of material violations of clear election law, and refusal to meet with honest citizen investigators, does not inspire trust. A full investigation must be launched immediately to determine the source of this active, confirmed, illegal attack compromising the validity of our elections.

“Free and honest elections are the very foundation of our republican form of govern- ment. Hence any attempt to defile the sanctity of the ballot cannot be viewed with equanimity.” United States v. Classic, 313 U.S. 299 (1941)

Summary of votes cast in New York’s 2022 general election by invalid or illegal registrations
These numbers were summed from a copy of NYSVoter dated 12/19/2022, after state level certification attested to the accuracy and legal compliance of the election. A blank address or unverified registrant could be allowed to vote in person after presenting ID, using an affidavit ballot. It is unknown at this time whether these 20,448 specific records were thus cured before voting. NY Citizens Audit can confirm that procedure was not universally followed in 2020; votes were cast by similarly invalid records for which there was no evidence provided, upon FOIL request, of curing.

Counterfeit registrations 449,856
Counterfeit registrations – DOUBLE+ VOTES 2,440
Registered after 2022 GE cutoff date, yet voted 9,766
Purged with no purge date 942
Purged before the election 2,524
Registered after last voted date 2,597
Voter identity never verified 3,825
Age discrepant registrants (older than the oldest known person in the US, 115yo) 599
Registered before age 16 2,032
Blank address registrants 16,623
January 1st registration, all years 1900-2022 254,090

January 1st Registration Votes
Two categories of invalid registration clearly dwarf the pool of suspicious votes: counterfeits and January 1st registration dates. Again in “False Claims Explained,” the state board of elections has provided an excuse for registrations created on federal holidays, 94% of which fall on New Years day:
Voters Registered on Federal Holidays
Voters that are pre-registered to vote will have their record activated on the day of their 18th birthday regardless of whether that date is a holiday. Additionally, if records did not have a registration date stamp when entering the voter into the electronic system, counties may have used January 1st as a placeholder day.
The “placeholder date” excuse attempts to cover provably false data in the voter rolls. Registration dates are material to determining eligibility to vote. When dates are false, the true date is unknown, and eligibility cannot be certain. Further, this does not explain why January 1st registration dates are assigned special ID numbers occupying key positions in the voter roll algorithms that Andrew Paquette, PhD reverse engineered, creating a highly complex and deliberate geometric pattern.

The following chart shows the first 24 rows of New York County data within NYSVoter, exactly as they originally appeared upon receipt of the data. Close inspection reveals that every tenth registration has:

1. an alphanumeric county ID number, unlike the other 9 in each set of 10;
2. a nearly consecutive state ID number, “short ID,” suggesting uniformity and nearly synchronous registration;
3. a registration date of 1/1/1984, twenty years earlier than the other 9 in each set of 10.

Given this array of contradictory charac- teristics, and the loss of control data breach, the “placeholder” date excuse is not plausible. Each of the January 1st registrant votes is strongly linked to provable fraud.

NY Citizens Audit has discovered several types of inexplicable data manipulation including missing votes and blank votes. The motive for these illegal changes is unknown. Each category requires immediate investigation.

Missing Votes:
According to NY election law, county and state voter rolls are real time replicas. The counties manage all registration records, and the state database is a compilation of each county’s accurate rolls. The following data sets were extracted from official records received via FOIL request:

County County voters who voted,
2020 GE NYSVoter 2020 GE votes, same unique voters
Bronx 48,998 0
55,134 0
New York (Manhattan) 49,166 0
55,036 0
Richmond 46,379 0

According to this data, there is a very real possibility that 254,713 voters were disenfranchised by the boards of elections. The NYSVoter database is considered the official record for administering federal elections, including voter history data. The state board of elections must provide a line-by-line audit regarding each of these unique voters, and prove what happened to their votes.

Blank Votes:
Another category of data manipulated post-certification is the count of blank ballots by county.9 Two counties stand out as having likely violations in this category, due to the magnitude of injections and subtractions. Although Westchester technically adjusted their data on the date of state certification, apparently squeezing in under the deadline, counties are required to turn their certified data over to the state at least a week in advance of that deadline for state attestation of accuracy and compliance. Additionally, it is unknown how Westchester could have legitimately scanned over half a million blank ballots.

County Blanks Changed
12/4/2020 Blanks Changed
12/8/2020 Blanks Changed
Orange -33,370 +36,584
+544,992 0

When $35,312 goes missing from your bank account, is that a clerical error?
The New York State board of elections publishes an official results document on their website after every election. It includes the total number of votes by race, county, and party. The total number of votes reported for the 2022 GE was 5,965,68410.

This number, however, has to have a basis in the raw data reported in NYSVoter, the official federal record11 of voter registration and participation. NY Citizens Audit received a copy of NYSVoter on 12/19/2022, four days after certification. When we tallied the voters who voted as recorded in NYSVoter, we were unable to reconcile the claim.

Official Source Reported Total
NYSBOE Official Results of 2022 GE report 5,965,684 votes cast
NYSVoter raw data, official federal document
5,930,372 voters who voted
35,312 more votes than voters who voted

Certification of New York’s 2022 general election appears to be a federal crime; a civil rights violation acting under color of law. Why?

Government by consent and the meaning of Certification
The King of America, the Law, is tethered to the Sovereign, the people, through the elective process. The loyalty of those we temporarily assign the privilege of writing and enforcing law is checked only by the honesty of our elections. Other- wise the King goes rogue. We cannot simultaneously have representative government and compromised elections.

Who is responsible for guaranteeing trustworthy elections? Under current federal law, each state has a chief election official who swears to and attests that an election is both accurate and legally compliant. This is the point of certification. Each of these individuals are bound to a sacred duty of maintaining valid, lawfully conducted elections, an incredible honor upon which our liberty pivots.

52 USC 20501 (National Voter Registration Act of 1993.)
SEC. 10. DESIGNATION OF CHIEF STATE ELECTION OFFICIAL. Each State shall designate a State officer or employee as the chief State election official to be responsible for coordination of State responsibilities under this Act.

SEC. 12. CRIMINAL PENALTIES. A person, including an election official, who in any election for Federal office—
(2) knowingly and willfully deprives, defrauds, or attempts to deprive or defraud the residents of a State of a fair and impartially conducted election process, by—
(A) the procurement or submission of voter registration applications that are known by the person to be materially false, fictitious, or fraudulent under the laws of the State in which the election is held; or
(B) the procurement, casting, or tabulation of ballots that are known by the person to be materially false, fictitious, or fraudulent under the laws of the State in which the election is held, shall be fined in accordance with title 18, United States Code, or imprisoned not more than 5 years, or both.

If citizens reading clear election law and auditing the NYSVoter database found materially false, fictitious, and fraudulent registrations and votes, the chief election official certainly knew or reasonably should have known about these violations, yet willfully chose to ignore, excuse or deny them.

A simple question
When officials certified New York’s federal elections in 2020 and 2022, did certification meet the federal standard of accuracy and compliance? To answer this, the law defining that standard must be reviewed.

There are two kinds of elections in America:

To be accurate, elections must meet extremely stringent standards. The allowable error rate in a federal election, in order for that election to be valid and therefore certifiable, is 1/10,000,000 ballot positions, or 1/125,000 ballots. According to the federal election assistance commission that set this legal standard, “This rate is set at a sufficiently stringent level such that the likelihood of voting system errors affecting the outcome of an election is exceptionally remote even in the closest of elections.”12 When it comes to federal elections, the law says there are no honest mistakes.

Was the 2022 election valid?
With a claim of 5,965,684 votes cast, the maximum allowable number of ballots in error for New York’s 2022 general election, in order to be a legally valid, compliant, certifiable election, is 48. NY Citizens Audit found 745,246 voting violations in excess of the legal standard.

Voting violations in the 2022 GE according to NYSBOE raw data 745,294
Allowable ballot errors for a valid federal election by law in 2022 GE 48

Unexamined history repeats itself
Disturbingly, the following related information regarding New York’s 2020 general election was substantially reported to the New York State board of elections on May 9, 2022, six months prior to the 2022 general election. No attempt was made to address the finding; it was dismissed outright and derided in the media. The certification of the 2022 general election proceeded under the same fraudulent conditions.

Voting violations in the 2020 GE according to NYSBOE raw data 960,546
Allowable ballot errors for a valid federal election by law in 2020 GE 70

New York’s 2020 and 2022 elections were not provably valid under the law.
Certification appears to be a federal crime, a civil rights violation acting under color of law.

Documents published by the NYS Comptroller as well as the Department of Defense Inspector General identify many of the issues presented in this report as probable cause for an investigation. The following guidance comes directly from the Inspector General13 and the NYS Comptroller14:

• Management override of key controls.
• Lost or destroyed electronic or hard copy records.
• Photocopied documents instead of originals.
• “Unofficial” electronic files or records instead of “archived” or “official” files or records.
• Revisions to electronic or hard copy documents with no explanation or support.
• Use of means of alteration to data files.
• Computer-generated dates for modifications to electronic files that do not fit the appropriate time line for when they were created.
• Computer report totals that are not supported by source documentation.

• Hostile relationship between management and internal and/or external auditors. This would include domineering behavior towards the auditor, failure to provide information, and limiting access to employees of the organization.
• Failure to establish procedures to ensure compliance with laws and regulations and prevention of illegal acts.
• Indications that key personnel are not competent in the performance of their assigned responsibilities.
• Inadequate resources to assist personnel in performing their duties, including personal computers, access to information, and temporary personnel.
• Failure to effectively follow-up on recommendations resulting from external reviews.
• A manager that claims disinterest or having no knowledge about a sensitive or high profile issue in which you would expect manage- ment involvement.
• Services paid for violated a Federal, state, or local statute or regulation.
• Original documentation consistently unavailable for the auditor’s review.
• Changes to the original documen- tation that do not appear to be authentic, such as different print or incorrect spacing.

RED FLAGS FOR FRAUD (parenthesis added)
• Management ignores irregularities.
• Staff lacks training.
• Reluctance to provide information to auditors.
• Management decisions are dominated by an individual or small group.
• Managers display significant disrespect for regulatory bodies.
• There is a weak internal control environment.
• Unexpected overdrafts or declines in cash balances (votes/voters).
• Photocopied or missing documents.
• Discrepancies between bank deposits and posting (deficits).
• Excessive number of voids.
• Increasing number of complaints about products or service.
• Lack of physical security over assets/inventory.
• No supporting documentation for adjusting entries.
• Forgery.
• Creating fictitious employees (voters) and collecting the paychecks (votes).
• Breach of Duty.
• Series of creative “explanations.”

1 Voter rolls must be accurate,
2 Votes counted must be from qualified electors,
3 The number of votes must equal the number of voters who voted,
were all materially violated in New York’s 2022 general election, as they had been in 2020.

On May 14, 1888, the United States supreme court issued an opinion, regarding an election matter in Indiana. Cited in
“Federal Prosecution of Election Offenses, Eighth Edition, December 2017,” it is still considered good law:

Congress seeks by this statute to guard the election of members of Congress against any possible unfairness by compelling, under its pains and penalties, everyone concerned in holding the election to a strict and scrupulous observance of every duty devolved upon him while so engaged… . The evil intent consists in disobedience to the law. (In re Coy, 127 U.S. 731)

Is this why the chief election official of New York has described the honest, completely volunteer effort of over 2,000 New York citizens as “malicious,” “false,” and done by “bad actors”15? Charged with the public trust and paid by the citizens they are sworn to serve, our election officials statewide have largely ignored the simple solution to meet with NY Citizens Audit. Instead, using the false mantle of their confiscated authority, they have announced our claims are “baseless,” and the provenance of our data is “fictional,” despite having provided it to us. Finally, without integrity or supporting evidence, they want us to take their word regarding our election outcomes.

The truth is, either by apathy, incompetence or malfeasance, election officials in New York have destroyed the validity of our elections. This is proven to have occurred in 2020 and 2022, at least. No one knows who won, by the will of the people, and the boards of elections are unable and unwilling to prove it to us. Our constitutional guarantee, of choosing the representatives we temporarily grant the privilege of writing and enforcing laws, via accurate, compliant elections, has been egregiously violated, and probable cause for an investigation has been demonstrated.

for both paper and electronic records, including ballots, by a mutually agreed upon external, third-party bonded auditing firm, possessed of adequate insurance and indemnification for the handling and protection of the personal identifying information of millions of New York citizens, in order to determine the true error rate. This audit will provide a compre- hensive report and analysis of all lapses and errors with explanation of cause where it can be determined.

We demand that this audit is completed well in advance of the upcoming 2024 primary and general elections, in order to successfully complete all needed repairs and ensure that the results of the 2024 elections are accurate, compliant, and trustworthy. Our domestic tranquility, as well as our responsibility to secure the blessing of liberty for the coming generations, requires it.

“The first grand right, is that of the people having a share in their own government by their representatives chosen by themselves, and, in consequence, of being ruled by laws, which they themselves approve, not by edicts of men over whom they have no control.”

From “A Letter to the Inhabitants of Quebec,” October 26, 1774, unanimously signed by the delegates to the First Continental Congress.

NY Citizens Audit Civic Fund, Inc is an all-volunteer, grassroots 501(c)3 organization that began auditing New York’s publicly available voter data in August of 2021. With over 2,000 citizens contributing, including specialists in auditing, data analytics, law, and cyber security, NY Citizens Audit has produced several significant reports. Our reports are designed to educate citizens, representatives, officials, and judges with an accurate, non-partisan assessment of New York’s voting system, based on election and civil rights law, both federal and state.

To obtain voter data, volunteers with NY Citizens Audit agree not to use the information for any non-election purpose. Therefore, NY Citizens Audit cannot provide specific voter data without an equal, binding agreement. Each of the voter records identified in this report as suspicious has been given to federal law enforcement and the New York State board of elections. If you require specific information beyond what is given in this report, and you are willing to sign a
non-disclosure agreement, please contact NY Citizens Audit at info@AuditNY.com.

1. Public Law 107–252, Help America Vote Act, 52 USC 21083, Sec. 303 (a)(2)(A)
2. Public Law 103-31, National Voter Registration Act, 52 USC 20501, Sec. 8 (i)(1)
3. Voting Systems Standards Volume 1: Performance Standards, Federal Election Commission United States of America, April 2002, Section 3.2.1; as referenced in 52 USC 21081(5).
4. NY Citizens Audit has received copies of the NYSVoter database and county voter roll databases, via Freedom of Information Law, from the boards of elections on multiple occasions. The first copy of NYSVoter was received on October 21, 2021.
5. US-CERT Federal Incident Notification Guidelines p. 4, “Impact Category Descriptions.”
6. This official BOE document can be read, along with NYCA responses, at
7. https://rumble.com/v2mar94-ny-citizens-audit-presents-to-nys-legislature-election-committees-may-1-202.html
8. https://www.jinfowar.com/journal/volume-22-issue-2/caesar-cipher-stacking-deck-new-york-state-voter-rolls
9. https://www.elections.ny.gov/2020ElectionResults.html Please see the sheet labeled “Revision History”
10. https://www.elections.ny.gov/2022ElectionResults.html
11. Public Law 107–252, Help America Vote Act, 52 USC 21083 Sec. 303 (a)(1)(A)(2)(ii & viii)
12. Voting Systems Standards Volume 1: Performance Standards, Federal Election Commission United States of America, April 2002, Section 3.2.1
13. US Department of Defense, Inspector General’s Office, “Comprehensive List of Fraud Indicators,” October 2017.
14. State of New York, Office of the State Comptroller, “Red Flags for Fraud.”
15. This official BOE document can be read, along with NYCA responses, at