An email to the FTC

Below you can find the email I just sent to the FTC, opposing the merger or acquisition plans of College Board and Carnegie Dartlet. The email address, should you wish to object, is

I am writing to express opposition to a proposed merger of, or acquisition by, The College Board /  Carnegie Dartlet Communications.  Although I have been working in admissions, financial aid and enrollment management at colleges and universities for almost 40 years (my affiliation is included below), I am sending this as a private citizen, and not as a representative of my current employer.

I am unable to find any reference to this proposed transaction on your website, but have been alerted to it by a recent story in Inside Higher Education.  Thus, the proposed details are not clear to me, so I am speaking in general terms.

Of initial concern is the framework that would allow a not-for-profit to merge with or acquire a for-profit company.  In fact, College Board is often described as “nominally not-for-profit,” and operates as a highly competitive entity with deep (and often troubling) connections inside the public primary and secondary educational systems in the US, and as such, collects massive amounts of data about students, which it then sells (technically “licenses”) to colleges to use in student recruitment.  Its status as a not-for-profit, the perception that College Board is somehow sanctioned by state governments via its testing contracts, and the trust these factors generate, allows mostly unfettered and unbridled ability of College Board to ensure students voluntarily supply this information.

The current president of the College Board, David Coleman, is often described as the architect of the Common Core, which was intended to serve as a national curriculum in America’s high schools (and thus, by extension, primary schools); it is no coincidence that the SAT (one of the main products of the College Board) is designed in conjunction with the tenets of Common Core, creating a business opportunity for College Board that purports to be in the best interest of students (as College Board is wont to describe most of their products and services.)

The fact that College Board has the cash and assets (including, apparently, billions of dollars in off-shore accounts) necessary to purchase a for-profit company should itself raise red flags.

Carnegie describes itself on its website as “the future of higher education marketing and enrollment strategy.”  The company touts its ability to measure unique motivators and behaviors of high school students.  They say their approach is “built on an unrivaled psychometric methodology” designed to elicit specific actions from students colleges are recruiting.

The combination of the College Board data, earned in good faith via its not-for-profit status, and the intrusive marketing tools of Carnegie Dartlet (which includes data on minors), equal bad news for student privacy; moreover, it creates an environment even more skewed toward making college just another consumer good, and toward making students and parents nothing more than customers in another sales transaction.

As someone who works in the industry, and as someone who already resents the intrusion of corporations into the process, I must object to this major step backwards for students in the process.

Unfortunately, the logical extension of this alliance would create for colleges a virtual competition-free monopoly on the recruitment process, in which institutions are beholden to the new entity to acquire information about prospective students.

It is important to see the larger and very concerning picture at play here.  I encourage you to squash this agreement, whatever its form, and ensure that higher education—and especially the students it serves and the data involved in the transactions between them—remain free of greater intrusion of bottom-line business interests.

If you wish to reach me, I can be contacted at or via cell phone at 541-908-7210.  I include a link to my professional affiliation only to lend some credence to my perspective, and not as an official endorsement of a position of my employer.

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