According to the anti-discrimination laws in force in USA (such as U.S. 34 CFR §100 and U.S. 34 CFR §110), the intentional discrimination can be proved directly or indirectly. The Arlington Heights mosaic of factors and/or the McDonnell Douglas framework can be used to prove indirectly the intentional discrimination (see here). Under the McDonnell Douglas test, the complainant(s) can prove the discrimination against him/her/them by showing that he/she is treated differently compared to similarly situated applicants outside his/her/their protected class(es). Presenting one or few similarly situated individuals outside his/her/their protected class(es) is already enough.

I am Randall Phillips, an African American over 40; I belong to two protected classes (race/origin protected class and age protected class). I have many groups of comparators that can be used to prove that, during the last 20 years period where I sought admission to graduate/PhD programs in Mathematics, Statistics, Economics, Finance and Actuarial Science, I have always been treated differently compared to similarly situated applicants outside my protected classes.

1 . Comparison of me with my non-underrepresented peers that are graduates of “Statistician and Economist Engineer ” training program of ENSAE Paris Tech

My first group of comparators is comprised of my non-underrepresented peers who graduated from “Statistician and Economist Engineer ” training program of ENSAE Paris Tech . The comparison of me with them does already show the flagrant discrimination against Blacks/African Americans like me: so far in more than 75 years of the history of the “Statistician and Economist Engineer ” training program of ENSAE Paris Tech, virtually all non-underrepresented graduates of the program who sought admission to graduate/PhD programs in USA have been offered admission; I graduated from the same "Statistician and Economist Engineer ” training program of ENSAE Paris Tech (i.e. I am Statistician and Economist Engineer), but admission officers of US universities treat me differently by denying me admission to graduate/PhD programs.

In fact, I am African American Math genius, first generation to go to College. I started taking College Mathematics courses since my 10th grade. My High School Mathematics courses include "Math Proofs" similar to Harvard University’s Math 55A and Math 55B (You can find here a sample of Mathematics exams I took when I was still in High School). I got an ETS recognition of excellence award in Mathematics (meaning that I am among the top 15% best graduates with Bachelor degrees in Mathematics in USA). I aced the rigorous, merit-based, standardized, written theoretical Mathematics competition examination for access to the prestigious “Statistician and Economist Engineer ” training program of ENSAE Paris Tech. A sample of the ENSAE Paris Tech’s Mathematics competition exams can be found here ("Mathématiques I" and "Mathématiques II" of "Filière MP") and/or here (Analysis on pages 1 to 4, and Linear Algebra on pages 4 to 6).

ENSAE Paris Tech is a prestigious French “Grande Ecole” of Economics and Statistics. In case you are not familiar with the “Grandes Ecoles” in France and in former French colonies in Africa, you can check here a document from Franco-American Commission for Educational Exchange (Fulbright Commission) that says, I quote, “The Grandes Ecoles, which are considered to be the pinnacle of French higher education, represent a sector of the educational system which is unlike anything known in American academia. They are very selective and prestigious schools of higher education... The admission to each Grande Ecole is strictly limited annually by the Board of each institution... In general, the best students who finish secondary school enroll in the courses for the preparation of the Grandes Ecoles entrance examination... This competitive entrance examination requires intensive preparatory work. A student seeking entrance to one of these schools may complete the work in two years. But three years is not unusual for preparation of the exam...”. The document of Fulbright Commission also says that, I quote, "In all the professional sectors of the French economy, employers often show a tendency to give preference to graduates of the Grandes Ecoles over graduates from the French universities". For example, in France, the "ingénieur"(engineer) graduates of "grandes ecoles" have higher salary compared to Masters and PhD graduates with no "grande ecole" diploma. In other words, in the eyes of French employers, the "ingénieur" diplomas from "grandes ecoles" are better indicators of competence and skills compared to Masters and PhD diplomas from universities. That's why only "grande ecole" graduates who want to do academic careers and/or who plan to work outside France do PhD studies. You also can check here the technical recruiter Martin Jee of Oxenbury Partners explaining in plein English that, I quote, “What exactly is a Grande Ecole and what does it mean?... Grandes Ecoles are the very, very best institutes for higher education that France has to offer; these institutions are so good, so well regarded, that they seem to be like winning the lottery of life… People who attended a Grande Ecole will be part of the top 5% of academic students in their year; they will be the very brightest students their generation has to offer. Each Grande Ecole is highly selective and the entry bar is made very high... certain Grandes Ecoles will only take the best of the best...”. Furthermore, not only ENSAE Paris Tech is a “grande ecole”, but it’s a tier 1 “grande ecole” too (the tier 1 "grandes ecoles, usually nicknamed "A+" schools, represent less than 1% of the higher education students in France). i.e. The “Statistician and Economist Engineer ” training program of ENSAE Paris Tech is the most prestigious and the most competitive “grande ecole” of Statistics and Economics. You can check here a publication of The Times Higher Education saying that ENSAE Paris Tech is one of 4 French “Grandes Ecoles” nicknamed “French MIT”. i.e. The Times Higher Education suggests that ENSAE Paris Tech graduates are fairly comparable to Honors graduates of Massachusetts Institute of Technology (MIT). On top of that, the “Statistician and Economist Engineer ” training program of ENSAE Paris Tech is a combined BS/MS Honors program with triple major in Mathematics, Statistics, and Economics.

In fact, the “Statistician and Economist Engineer” training program of ENSAE Paris Tech has been especially designed for Math genius who plan to do graduate/PhD studies and careers in Statistics, Economics, Finance, and Actuarial Science. Top ranking PhD programs in Statistics, Economics, Finance and Actuarial Science in USA do all use manuals of the "Statistician and Economist Engineer" training program of ENSAE Paris Tech (English versions of the manuals initially written in French) such as "The Theory of Corporate Finance" by Professor Jean Tirole (2014 Nobel Economics laureate) and published by Princeton University Press, "The Theory of Industrial Organization" by Professor Jean Tirole and published by MIT Press, "The Theory of Incentives: The Principal-Agent Model" by late Professor Jean-Jacques Laffont and published by Princeton University Press, "The Economics of Uncertainty and Information" by late Professor Jean-Jacques Laffont and published by MIT Press, "Fundamentals of Public Economics" by late Professor Jean-Jacques Laffont and published by MIT Press, "Financial Econometrics: Problems, Models, and Methods" by Professor Christian Gourieroux and published by Princeton University Press, "Simulation-Based Econometric Methods" by Professor Christian Gouriéroux and Professor Alain Monfort and published by Oxford University Press, "Statistics and Econometric Models: Volume 1, General Concepts, Estimation, Prediction and Algorithms" and "Statistics and Econometric Models: Volume 2, Testing, Confidence Regions, Model Selection and Asymptotic Theory" by Professor Christian Gourieroux and Professor Alain Monfort and published by Cambridge University Press, etc.

In more than 75 years of the history of the “Statistician and Economist Engineer ” training program of ENSAE Paris Tech, a non-underrepresented graduate of the program never has been denied admission into a graduate/PhD program in the USA. I graduated from the “Statistician and Economist Engineer” training program of ENSAE Paris Tech; but PhD admission staff of U.S. universities treat me differently by denying me access to PhD study. More precisely, during the last 20 years period, I submitted more than 100 applications for admission to PhD programs in Mathematics, Statistics, Economics, Finance, and Actuarial Science (giving an average of about 5 applications per year during 20 years straight); but all the admission staff denied me admission, whereas my non-underrepresented ENSAE Paris Tech graduate peers submitted only 5 or less applications and got multiple admission offers from top ranking universities such as MIT, Harvard, Yale, Cornell, NYU, Columbia, Princeton, UPenn, UChicago, Northwestern, Stanford, UC-Berkeley, and UCLA. There is an unwritten agreement between ENSAE Paris Tech and these top ranking universities to admit the graduates of ENSAE Paris Tech who want to do graduate/PhD studies; but the admission staff of these top ranking US universities violate the unwritten agreement when a Black/African American ENSAE Paris Tech graduate like me apply for admission. Adding insult to injury, the different treatment against Black/African American like me has always been wrongfully backed by investigators of the Office for Civil Rights (OCR) of U.S. Department of Education.

For instance, since more than a half century, Princeton University has routinely admitted non-underrepresented ENSAE Paris Tech graduates to do graduate/PhD studies in Economics, Finance, and Financial Engineering. If you visit Princeton University, you should always find non-underrepresented ENSAE Paris Tech graduates studying there. For example, Samya Aboutajdine (ENSAE class of 2021) and Nicolas Hommel (ENSAE class of 2020) are currently studying there doing PhD study in Economics and Finance. Princeton University does also know that ENSAE Paris Tech alumni are exceptionally competitive in research activities in Statistics, Economics, and Finance. For example, when the former Chairman of Federal Reserves, Ben Bernanke (2022 Nobel Economics laureate), created in 1997 the Bendheim Center for Finance at Princeton University, an ENSAE Paris Tech alumnus, Professor Yacine Ait-Sahalia, was called to be the inaugural Director of the newly created research center. i.e. People at Princeton University know that ENSAE Paris Tech graduates are exceptionally qualified and competitive for both PhD studies and research careers in Statistics, Economics and Finance. So, when in Fall 2004 Professor Shirley Tilghman, the then President of Princeton University, saw I was an ENSAE Paris Tech graduate seeking to do PhD study, she asked me to do my PhD study in Economics at her university. She said Princeton University needed people to do research. In other words, not only did Professor Tilghman know I was qualified for the PhD program in Economics of Princeton University, but she also knew that an ENSAE Paris Tech graduate like me was exceptionally competitive in research activities in Economics and Finance compared to other qualified applicants who were not ENSAE Paris Tech graduates. However, the respective admission staff didn’t admit me when they learned my race and/or origin. When the new President of Princeton University, Professor Christopher Eisgruber, learned admission staff didn't let me in, he did an internal investigation. In the beginning of his internal investigation, the admission staff apparently lied to him by alleging that I had never applied for admission to Princeton University’s PhD programs. Fortunately, Professor Christopher Eisgruber forwarded to me the email he received from his admission staff; and I could submit rebuttals by providing Professor Christopher Eisgruber additional information. After receiving my rebuttals, Professor Christopher Eisgruber saw I was right and his admission staff lied and/or did not tell all the facts. This situation was one of the reasons that led Professor Christopher Eisgruber to affirm in 2020 that admissions staff of Princeton University discriminated against underrepresented minorities. Unfortunately, Professor Eisgruber couldn’t stop his admission staff from excluding qualified Blacks/African Americans like me from participating to PhD programs of Princeton University because OCR investigators directly and/or indirectly unlawfully backed the admission staff excluding qualified Blacks/African Americans like me.

Similarly, since more than a half century, University of Chicago has always admitted non-underrepresented ENSAE Paris Tech graduates to do graduate/PhD studies in Statistics, Economics, and Finance. For example, when I first submitted an application for admission to PhD program in Economics of University of Chicago in Fall 2004, I saw a non-underrepresented ENSAE Paris Tech graduate François Gourio (ENSAE class of 2000) doing a PhD study in Economics there at the University of Chicago. I mean if you visit University of Chicago, there are always non-underrepresented ENSAE Paris Tech graduates there, either doing graduate/PhD study or doing research in Statistics, Economics and Finance; and they always excel in their study and/or research. So, in February 2005, when the Chairman of the Department of Economics of University of Chicago saw I was an ENSAE Paris Tech graduate applying for admission to his PhD program in Economics, he directly proposed a Research Assistant position to me. i.e. Not only did he know I was qualified for his PhD program in Economics, but he also knew that an ENSAE Paris Tech graduate like me was exceptionally competitive in research activities in Economics and Finance compared to other qualified candidates who were not ENSAE Paris Tech graduates. However, the university’s admission staff rescinded the admission offer when they learned my race and/or origin. They only admitted non-underrepresented ENSAE Paris Tech graduates such as Khalil Dayri (ENSAE class of 2005) that also sought admission to University of Chicago that year 2005 and got admitted. So far, the graduate/PhD admission discrimination practice against Blacks/African Americans like me has always been wrongfully backed by investigators of OCR Office in Chicago, IL such as Marcela Sanchez-Aguilar (Supervising Attorney), Melissa Howard (Supervising Attorney), Aaron Chait (Attorney), and Christopher Farrelly (Attorney).

Similarly, almost each year, University of California-Berkeley admits my non-underrepresented ENSAE Paris Tech graduate peers. For instance, UC-Berkeley’s current 2023 graduate students Alexandre Caduc, Mélanie Fabiani, Sofiane Bessaoud, Elisa Piaraly, Nathan Boyer, Maxime Bäumler, Felipe Montenegro, Yassine Sbai Sassi, and Kevin Dano are all non-underrepresented ENSAE Paris Tech graduates (and they are in their 20s and/or early 30s). However, during the last 20 years period, UC-Berkeley has always refused to admit me to its graduate/PhD programs. In particular, the current Chair of the PhD program in Finance of UC-Berkeley, Professor David Sraer, is an ENSAE Paris Tech alumnus like me. i.e. He knows that an ENSAE Paris Tech graduate like me is exceptionally qualified and competitive for PhD study and research activities in Economics and Finance. However, Professor Sraer and his admission staff don’t let me in. Similarly, Professor Ann Harrison, the current Dean of Haas School of Business of UC-Berkeley, started in France her College study. Unlike me, she didn’t have enough Mathematics and/or Economics knowledge and skills for an admission to ENSAE Paris Tech; she then transferred to UC-Berkeley to get a BA in Economics and eventually got admitted to PhD program in Economics of Princeton University. i.e. Professor Harrison knows very well that an ENSAE Paris Tech graduate like me is more than qualified for the PhD program in Finance of her school. However she backs her admission staff denying me admission. Similarly, the Executive Vice Chancellor and Provost of UC - Berkeley, Professor Benjamin Hermalin, is also a Professor of Economics and Finance; so, he knows very well that, with my combined BS/MS Honors degree with triple major in Mathematics/Statistics/Economics, I am exceptionally qualified and competitive for the PhD programs in Economics and Finance of UC-Berkeley. To sum up, all people in charge of the PhD programs in Economics and Finance at UC-Berkeley know that an ENSAE Paris Tech graduate like me is qualified and competitive for the PhD programs in Economics and Finance of UC-Berkeley; but they don't let me in. When I asked them why they don’t let me in, the admission office of Haas School of Business told me to let them alone. i.e. They think their PhD programs in Economics and Finance are not for people of my race/origin/age despite the fact they admit my ENSAE Paris Tech graduate peers outside my protected classes. And so far, this different treatment against Blacks/African Americans like me has always been condoned by Professor Carol Christ (Chancelor of UC-Berkeley) and wrongfully backed by OCR investigators such as Anamaria Loya (Chief Attorney) and James Wood (Attorney) of the OCR Office in San Francisco, CA.

2 . Comparison of me with other admitted PhD applicants who are not ENSAE Paris Tech graduates

My second group of comparators is comprised of the admitted PhD applicants that are not ENSAE Paris Tech graduates. Let’s take the case of non-underrepresented applicants admitted to PhD programs in Economics and Finance. In case you don’t know, Finance is a sub-field of Economics; that’s why some Economists prefer calling it Financial Economics.

For instance, you can check the current students of the PhD program in Finance of Sloan School of Management of MIT. As you can see, non-underrepresented students Enzo Bastos Profili, Quentin Batista, Maya Bidanda, Marta Bilghese, Brice Green, Joanne Im, Giuditta Perinelli, Maria Tiurina, Yevhenii Usenko and Xin Xiong did all major in only Economics (they didn't major in Mathematics nor Statistics); so, they were far from an ideal candidate for the PhD program in Finance; but admission staff preferred admitting them rather than admitting an African American ideal candidate like me. Some of the non-underrepresented PhD students in Finance did major in Mathematics and/or Statistics (Patrick Adams, Jack Li, Jiageng Liu, Yury Olshanskiy, J. R. Scott, and John Wilson, etc.); but, unlike me, they didn't have indisputable proof of excellence in Mathematics and quantitative fields. For example, they didn't have ETS recognition of excellence award in Mathematics; almost the totality of them can't pass the Math competition examination for access to the "Statistician and Economist Engineer" program of ENSAE Paris Tech (they can't even pass the Math competition examination for access to tier 2 "grande ecole" of Economics and Statistics (see Chapter #6 below)); similarly the majority of them don't have enough Math and Statistics skills to pass SOA/CAS actuarial certification exams (see Chapter #3 below); and almost the totality of them still needed Math/Statistics summer camp in July-August before starting their PhD study in Finance in September. More generally, each year, the majority of applicants admitted to the PhD programs in Economics and Finance of MIT are (younger, non-underrepresented) candidates who are less qualified than me in the sense they are not ideal candidates for the PhD programs in Economics and Finance whereas I am; but admission staff of MIT always prefer admitting them rather than admitting the better qualified Black/African American candidates like me. Adding insult to injury, this PhD admission discrimination practice of MIT against qualified Blacks/African Americans like me has always been wrongfully backed by OCR investigators such as Michelle Kalka (Compliance Team Leader) and Gillian Thompson (Attorney) of OCR Office in Boston, MA.

Similarly, you can check the PhD applicants admitted each year to Harvard (PhD program in Business Economics, PhD program in Economics), Boston College (PhD program in Economics, PhD program in Finance), Yale (PhD program in Economics, PhD program in Finance), Brown (PhD program in Economics), URochester (PhD program in Economics, PhD program in Finance), Cornell (PhD program in Economics, PhD program in Finance), NYU (PhD program in Economics, PhD program in Finance), Columbia (PhD program in Economics, PhD program in Finance), Princeton (PhD program in Economics, PhD program in Financial Engineering), UPenn (PhD program in Economics, PhD program in Finance), PennState (PhD program in Economics, PhD program in Finance), Carnegie Mellon (PhD program in Economics, PhD program in Finance), Georgetown (PhD program in Economics), Duke (PhD program in Economics, PhD program in Finance), UNC-Chappel Hill (PhD program in Economics, PhD program in Finance), Emory (PhD program in Economics, PhD program in Finance), Ohio State (PhD program in Economics, PhD program in Finance), UMichigan-Ann Arbor (PhD program in Economics, PhD program in Finance), IndianaU-Bloomington (PhD program in Economics), UIllinois-Urbana-Champaign (PhD program in Economics, PhD program in Finance), UChicago (PhD program in Economics, PhD program in Finance), Northwestern (PhD program in Economics, PhD program in Finance), UW-Madison (PhD program in Economics, PhD program in Finance, PhD program in Insurance Economics and Actuarial Science), UMinnesota (PhD program in Economics), UIowa-Iowa City (PhD program in Economics), WashingtonU-St Louis (PhD program in Economics, PhD program in Finance), UTexas-Austin (PhD program in Economics, PhD program in Finance), Stanford (PhD program in Economics, PhD program in Finance), UC-Berkeley (PhD program in Economics, PhD program in Finance), UCLA (PhD program in Economics, PhD program in Finance), UC-Davis (PhD program in Economics), UC-San Diego (PhD program in Economics), etc. None of candidates admitted each year to these PhD programs in Economics and Finance are better qualified than a Black/African American ideal candidate like me; i.e. either they are less qualified than me, or they are as qualified as me. About half of them or more did major in only one academic field such as Economics or Mathematics; thus, they are far from an ideal candidate for the PhD programs in Economics and Finance; but admission staff prefer admitting those less qualified (younger, non-underrepresented) applicants rather than admitting a better qualified Black/African American candidate like me.

For instance, this year 2023, the PhD program in Finance of UC-Berkeley admitted younger, non-underrepresented minority Hanna Yu and William Zhang: they did major in only Mathematics but not Economics nor Statistics; so, they were less qualified than an ideal candidate like me; but admission staff preferred admitting them rather than admitting me. Similarly, this year 2023 the PhD program in Finance of Stanford University admitted (younger, non-underrepresented) Miguel Chumbo, Francesco Spizzuoco, and Chun Zhao; these applicants did all major in only Economics but not Mathematics nor Statistics; so, they were less qualified than a Black/African American ideal candidate like me; but admission staff preferred admitting them rather than admitting me. Similarly, the PhD program in Finance of University Chicago admitted younger, non-underrepresented Rahul Singh Chauhan this year 2023: he majored in only Economics but not Mathematics nor Statistics; so, he was less qualified than a Black/African American ideal candidate like me; but admission staff preferred admitting him rather than admitting me. The best candidates admitted this year 2023 by the PhD programs in Economics and Finance of University of Chicago were Tanvi Jindal and Tyler Patterson who have Bachelor degree with double major in Economics and Mathematics; but they were still not better qualified than a Black/African American ideal candidate like me who have combined BS/MS degree with triple major in Mathematics, Economics, and Statistics. For instance, the most advanced Math courses Tanvi Jindal took were MAT321-Foundations of Abstract Algebra and MAT316-Foundations of Analysis; and they are comparable to Math courses I took when I was still in High School. Tanvi Jindal can't even pass the Math competition examination for access to tier 2 "grande ecole" of Economics and Statistics (see the last paragraph of Chapter #6 below). In Economics, the most advanced courses Tanvi Jindal took were ECN280-Microeconomic Analysis and ECN282-Macroeconomic Analysis; and they are comparable to my Introductory Microeconomics course and Introductory Macroeconomics course during my 1st year study at the "Statistician and Economist Engineer" training program of ENSAE Paris Tech. Similarly, the best candidates admitted this year 2023 by the PhD program in Finance of University of Pennsylvania were non-underrepresented minority Sese Nguyen (who graduated from University of Connecticut with Bachelor degree with double major in Economics and Statistics) and foreign student Fernando Stein Vallarta (who graduated from Autonomous Institute of Technology of Mexico (ITAM) with Bachelor degree with double major in Economics and Applied Mathematics). These (younger non-underrepresented) applicants still weren't ideal candidates for the PhD program and research career in Finance and they still needed an intensive 120 clock hours of Summer Math camp in July-August 2023 before starting their PhD study in September 2023 whereas I am an ideal candidate and I did already do all the coursework of the Summer Math camp of University of Pennsylvania. Similarly the PhD program in Business Economics of Harvard University admitted younger, non-underrepresented Lev Klarnet, Nathan Kaplan and Catherine Huang who majored in only Economics; but the admission staff preferred admitting these less qualified applicants rather than admitting a better qualified Black/African American ideal candidate like me who majored in the 3 fields Mathematics/Statistics/Economics,. The best candidate admitted in 2023 by Harvard University was Brianna Alderman: she has BA in Economics, BS in Mathematics, and BS in Statistics from University of Florida. But Brianna Alderman still wasn't better qualified than me. In fact, the most advanced Economics courses she took at University of Florida are comparable to my Introductory Microeconomics and Introductory Macroeconomics courses I took during my 1st year study at the "Statistician and Economist Engineer" training program of ENSAE Paris Tech. The most advanced Math courses she took at University of Florida are comparable to Math courses I took when I was still in High School. The most advanced Statistics courses she took at University of Florida are comparable to the Introductory Statistics course I took during my 1st year study at the "Statistician and Economist Engineer" training program. She also still needed Summer Math camp in Mathematics and Summer Math camp in Statistics before starting her PhD study in Business Economics in September 2023.

It’s also worth noting that, on top of discriminating against Blacks/African Americans, the admission staff do also lie to the public, to the United States Congress, and to the federal and state governments by alleging that the main reason of the underrepresentation of Blacks/African Americans in PhD in Economics and Finance is because there is no qualified Blacks/African Americans to do PhD studies in Economics and Finance and/or the qualified Blacks/African Americans don’t want to do PhD studies in Economics and Finance. For instance, facing criticisms of the inexistence of African Americans working at the federal reserve, the President of federal reserve of Richmond (Thomas Barkin) said, I quote, “We work hard on diversity every day… Part of that is going to HBCUs and attracting people into our organization as research analysts into the economics department with the idea of convincing them to go get PhDs.” (see here ). He implied and/or alleged that the qualified African Americans don’t want to do PhD studies in Economics and Finance. However, as you can see with my above-mentioned case, the fact tells a different story and Thomas Barkin is misinformed if not a flagrant liar: there are thousands of qualified Black/African American candidates who want to do PhD studies in Economics and Finance (I am one of them), but the admission officers deny us admission despite our qualification; admission staff prefer admitting less qualified and/or equally qualified non-underrepresented candidates. By the way, about 10 years ago, I saw a non-underrepresented ENSAE Paris Tech graduate working for the federal reserve of Richmond; she is not Black (she is non-underrepresented minority); so, she easily got admitted to a PhD program in Economics of an ivy league university on East Coast. Similarly, this year 2023 I saw 2 ENSAE Paris Tech graduates working at the federal reserve of Chicago; they are non-underrepresented majority persons; so, they easily got admitted to the PhD program in Economics of University of Minnesota- Twin City and to the PhD program in Economics of University of Chicago.

3 . Comparison of me with admitted applicants through SOA/CAS actuarial certification exams

The different treatment against me can also be viewed through actuarial certification exams of the Society Of Actuaries (SOA) and Casualty Actuarial Society (CAS). In fact, Actuarial Science is Mathematics, Statistics, Economics and Finance used in insurance and finance industry. SOA/CAS actuarial certification exams (such as Exam 1/Probability, Exam 2/Financial Mathematics, Exam 3/Financial Economics, etc.) are merit-based and standardized examination that measure the candidate’s knowledge and skills in these academic fields. You can check the web site of the Office of Personnel Management (OPE) of federal government, Actuarial Science, Series 1510: a federal government employee with Bachelor degree in Mathematics, Statistics, Economics, Finance or Actuarial Science is paygrade GS-5; a federal government employee with 1 actuarial certification exam of SOA/CAS is paygrade GS-7 above GS-5/Bachelor degree; a federal government employee with 2 actuarial certification exams of SOA/CAS is paygrade GS-9 comparable to GS-9/Masters degrees in Mathematics, Statistics, Economics, Finance, and Actuarial Science; a federal government employee with 3 actuarial certification exams of SOA/CAS is paygrade GS-11 comparable to PhD degree; and a federal government employee with 4 actuarial certification exams of SOA/CAS is paygrade GS-12 above GS-11/PhD in Mathematics, above GS-11/PhD in Statistics, above GS-11/PhD in Economics, above GS-11/PhD in Finance, above GS-11/PhD in Actuarial Science, etc. In other words, the rule in USA is simple and straightforward: a person with more SOA/CAS actuarial certification exams can’t be less qualified than a person with less SOA/CAS actuarial certification exams. I have more than 4 SOA/CAS actuarial certification exams; thus, I can’t be less qualified than applicants with less than 4 SOA/CAS actuarial certification exams. i.e. I am better qualified than and/or as qualified as the applicants with just a Bachelor degree in Mathematics, Statistics, Economics, Finance, or Actuarial Science. On top of that, in more than 100 years of the history of the American actuarial profession, there has never been a non-underrepresented person with 4 or more SOA/CAS actuarial certification exams denied admission to PhD programs. Unfortunately, admission staff and OCR investigators constantly violate this rule and practice when Blacks/African Americans like me apply for admission to PhD programs in Mathematics, Statistics, Economics, Finance, and Actuarial Science: the admission staff always prefer admitting younger, non-underrepresented applicants with none or less SOA/CAS actuarial certification exams rather than admitting Blacks/African Americans like me with more SOA/CAS actuarial certification exams; and the admission discrimination practice against Blacks/African Americans like me has always been wrongfully backed by OCR investigators. You can check the non-underrepresented PhD students in Statistics, Economics, Finance and Actuarial Science at top ranking U.S. universities such as MIT, Harvard, Yale, NYU, Columbia, Princeton, UPenn, UChicago, Northwestern, UW-Madison, Stanford, UC-Berkeley, UCLA, etc.; almost the totality of them have none or less SOA/CAS actuarial certification exams; but admission staff preferred admitting them rather than admitting Blacks/African Americans like me with more than 4 SOA/CAS actuarial certification exams.

Let’s take the specific example of University of Pennsylvania that have a concentration in Actuarial Science and related fields. I have been seeking admission to the PhD programs in Statistics, Economics and Finance of University of Pennsylvania since 2005; but so far, the admission staff have always preferred admitting less qualified non-underrepresented applicants with none or less SOA/CAS actuarial certification exams than mine. You can check here the current non-underrepresented PhD students in Finance of University of Pennsylvania: virtually all of them have none or less SOA/CAS actuarial certification exams than mine; but the admission staff preferred admitting those less qualified non-underrepresented applicants rather than admitting a better qualified Black/African American applicant like me with more than 4 SOA/CAS actuarial certification exams. Adding insult to injury, the admission discrimination against Blacks/African Americans like me has always been backed by OCR investigators such as Christina Haviland (Supervisory Attorney) and Jerry Hand (Attorney) of the OCR Office in Philadelphia, PA.

Similarly, I applied for admission to the PhD program in Economics of University of Wisconsin – Madison (UW-Madison). The university’s admission officers denied me admission despite me being an ideal candidate for the PhD program in Economics; the admission staff preferred admitting less qualified (younger, non-underrepresented) applicants who were far from an ideal candidate for the PhD program in Economics. I then applied for admission to the UW-Madison’s PhD program in Insurance Economics and Actuarial Science. I recall that a candidate with more SOA/CAS actuarial certification exams can’t be less qualified than the candidates with less SOA/CAS actuarial certification exams (see here). However, the university’s actuarial scientists broke their rule: they rejected me and they preferred admitting (younger, non-underrepresented) applicants with less SOA/CAS actuarial certification exams (see the current PhD students here, almost all of them have less than 4 actuarial certification exams). In particular, the faculty in charge of the PhD program at that time, Professor Peng Shi , did offer admission almost exclusively to foreign applicants of his race/origin (see the current PhD students here, almost all of them have the same race and origin). I then decided to apply for admission to the university’s Finance PhD program. However, the then Director of Admissions and Recruitment of PhD Programs for Wisconsin School of Business, Patrick Stevens , didn’t submit my application to the admission officers for review anymore. And this admission practice against Blacks/African Americans like me has always been condoned (if not backed) by the Chancelor and by the Provost of University of Wisconsin – Madison.

Similarly, I applied for admission to the following PhD programs in Actuarial Science: PhD program in Mathematics with thesis in Actuarial Science of UW-Milwaukee, PhD program in Statistics with concentration in Actuarial Science of UIowa - Iowa City, PhD program in Mathematics with concentration in Actuarial Science of UIllinois -Urbana Champaign, PhD program in Risk Management and Insurance (RMI) of Temple University, PhD program in Mathematics with thesis in Actuarial Science of UConnecticut – Storrs, and PhD program in Statistics and Applied Probability with emphasis in Financial Mathematics and Actuarial Science of University of California - Santa Barbara. Not only am I qualified for these PhD programs in Actuarial Science, but I also can directly pass PhD qualifying examination and finish the PhD study in 2 to 3 years instead of 4 to 6 years. You can check the applicants admitted each year to these PhD programs: almost all of them have the same race and origin as the actuarial scientists in charge of the admission selection; and virtually all of them are also younger, non-underrepresented applicants with less than 4 SOA/CAS actuarial certification exams. Therefore, they don't belong to my protected classes and they are not better qualified than an African American ideal candidate like me who have 4 or more SOA/CAS actuarial certification exams. However, the actuarial scientists of these universities violate their above-mentioned rule/practice and deny me admission despite me having more SOA/CAS actuarial certification exams. The actuarial scientists keep maintaining their admission practice against Blacks/African Americans like me because OCR investigators keep wrongfully backing them.

4 . Other facts directly and/or indirectly proving PhD admission discrimination intent and practice against Blacks/African Americans like me

Empowered by the OCR investigators' support, graduate/PhD admission staff use countless pretexts to exclude qualified Blacks/African Americans from participating to graduate/PhD programs in Mathematics, Statistics, Economics, Finance, and Actuarial Science.

For instance, when I first applied for admission to the PhD program in Economics of University of Maryland - College Park in 2005 (it was an affirmative action university at that time), the admission staff denied me admission by alleging my GRE Verbal score was “low”. I addressed the stated “weakness” by sitting again for the GRE test to improve my GRE Verbal score and I reapplied for Fall 2006 admission. However, they still denied me admission by alleging my GRE Quantitative score was “low”. I sat again for the GRE test to get a perfect GRE Quantitative score and I reapplied again for Fall 2007 admission. The admission staff still didn’t admit me by alleging again that my GRE Verbal score was “low”. I went to investigate on site at University of Maryland - College Park campus; and I found out that the PhD program in Economics of University of Maryland - College Park had always admitted non-underrepresented candidates with lower GRE Verbal scores than mine and with lower GRE Quantitative scores than mine. Then, I decided to file a discrimination complaint with the OCR Office in Philadelphia, PA. The spokesperson of the admission staff of the university - Professor Judith K. Hellerstein (former Chair of the Department of Economics of University of Maryland - College Park) – responded to my admission discrimination charge. However, she abandoned again the allegation of “low” GRE scores. Instead, she insulted me, my school and my recommenders ( ENSAE Paris Tech alumnus & PhD in Mathematics graduate of University Paris – Saclay; PhD in Economics graduate of UC-Berkeley; and PhD in Economics graduate of UPenn) by alleging that I didn’t have enough Mathematics and Economics knowledge and skills for the PhD study in Economics. I recall that I took advanced theoretical Math courses since High School (here is a sample of my High School Math exams); I aced the merit-based standardized theoretical Math competition examination for access to the “Statistician and Economist Engineer” training program of ENSAE Paris Tech (here is a sample of the Math competition exams of the program); the program is a combined BS/MS Honors program with triple major in Mathematics, Statistics, and Economics; and the graduates of the program are fairly comparable to Honors graduates of MIT (see the affirmation of The Times Higher Education mentioned earlier above); in particular, I did already successfully take up to 2nd year PhD courses in Economics during my 2nd year class of the Statistician and Economist Engineer training and during my specialization in “Economic Policies and Dynamics” of the program; and I graduated with Honors, etc. But Professor Judith K. Hellerstein still alleged that I didn’t have enough Mathematics and Economics knowledge and skills for the PhD study in Economics. For those of you who are familiar with the French academic grading, I got a GPA of 14.75/20 during an academic year of the Statistician and Economist Engineer training; i.e. most of my grades were above 14 and I got “Mention Bien” Honors (the highest Honors that students could get that year; College students who succeed to get the "Mention Bien" Honors are extremely rare; "Mention Bien" Honors is fairly comparable to President's list at US universities). But Professor Judith K. Hellerstein said my grades were “low” whereas she considered the non-underrepresented students with the lower "Mention Assez-Bien" Honors to have high grades. More precisely, Professor Hellerstein didn’t deny that my non-underrepresented ENSAE Paris Tech graduate peers have enough Mathematics and Economics knowledge and skills for the PhD program in Economics (the PhD program in Economics of University of Maryland – College Park admitted non-underrepresented ENSAE Paris Tech graduates, including those with lower GPA than mine and/or those with lower Honors “Mention Assez-Bien”). However, she, Professor Hellerstein, said she didn’t believe I had enough Mathematics and Economics knowledge and skills for the PhD program in Economics; and the unspoken reason she “didn’t believe” I was as skilled as my non-underrepresented peers is because of my race and/or origin. She said the PhD program in Economics of University of Maryland – College Park is among the top 20 best PhD programs in Economics in USA: she was alleging/implying that people of my race and/or origin don’t have enough Mathematics and Economics knowledge and skills for the top 20 best PhD programs in Economics in USA. These affirmations of Professor Hellerstein speak for themselves for her racism and discrimination against Blacks/African Americans like me. Unfortunately, the investigators of the OCR Office in Philadelphia, PA unlawfully backed the racism and discrimination of Professor Hellerstein against the Blacks/African Americans like me.

Moreover, it is worth noting that, during my Statistician and Economist Engineer study, I did already successfully complete all the Mathematics coursework and all the Statistics coursework that can be used in the PhD studies and research careers in Economics and Finance (such as Functional and Convex Analysis; Optimization; Measure Theory and Lebesgue Integral; Measure-based Theory of Probability; Introduction to Graduate Statistics; Graduate Mathematical Statistics Theory 1; Graduate Mathematical Statistics Theory 2; Bayesian Statistics Theory; Theory of Non-parametic Estimation and Testing; Theoretical Foundations of Machine Learning; Applied Statistical Learning; Graduate Mathematics of Finance; Introduction to Stochastic Process ; Graduate Stochastic Calculus; Financial Instruments; Interest Rate Curve Models, Simulation and Monte Carlo Methods, etc.). I did also already successfully complete all the Econometrics coursework for the PhD programs in Economics and Finance (Graduate Econometrics 1; Graduate Econometrics 2; Graduate Time Series Analysis; Advanced Econometrics Theory: Panel Data and Duration Models; Statistical Methods of Econometrics; Econometrics of Competition; Financial Econometrics; GARCH and Stochastic Volatility Models, etc.). And I did also already successfully take all the Microeconomics coursework and all the Macroeconomics coursework of the 1st year class of the PhD programs in Economics and Finance (such as Microeconomics Theory 1; Microeconomics Theory 2; Game Theory; Theory of Industrial Organization ; Business Economics, Organization and Incentives; Finance Microeconomics; Microeconomic Theory of Insurance; Macroeconomics Theory 1; Macroeconomics Theory 2; Recursive Methods in Macroeconomics, etc.). So, I requested to directly sit for and pass the qualifying examination of the PhD programs in Economics and Finance of University of Maryland – College Park in order to further proving that the allegation of Professor Hellerstein is a lie and/or discrimination. Instead of letting me sitting for the PhD qualifying examination, admission staff of University of Maryland – College Park asked me to submit again an application for admission because they said I had been “offered” an admission. However, when I submitted again an application for admission to the PhD program in Finance of University of Maryland – College Park, they still denied me admission. In other words, they lied again when they told me I had been offered an admission. The truth is, after I asked to directly pass the PhD qualifying examination of the PhD programs in Economics and Finance, they abandoned their allegation of my lack of knowledge and skills for the PhD study: when they asked me to submit again an application, their true intent was not to admit me, but to get a new pretext. I don’t know their new pretext because the investigators of the OCR Office in Philadelphia didn’t let the admission staff to respond to my charge anymore. All I know is the OCR investigators directly dismissed my complaint by wrongfully alleging that there is not enough fact that allows OCR to infer that the admission staff engaged in a discrimination practice against me. In other words, the OCR investigators knowingly, intentionally, willfully violated again their legal standard and directly dismissed my complaint without asking University of Maryland to respond to my charge.

Similarly, after getting multiple PhD admission denials by admission staff of MIT, I also asked to directly pass the PhD qualifying examination of the PhD programs in Economics and Finance of this university. I recall that ENSAE Paris Tech graduates are fairly comparable to BS/MS Honors graduates of MIT, and I already took up to 2nd year PhD courses in Statistics, Econometrics, Economics and Finance during my “Statistician and Economist Engineer” training (see my core courses here and here ). The Dean of Sloan School of Management of MIT, Professor David Schmittlein, responded negatively to my request to directly pass the PhD qualifying examination. More precisely, he didn’t deny I have the knowledge and skills to directly pass the PhD qualifying examination; but he said my ability to directly pass the qualifying examination doesn’t prove I am qualified for the PhD programs in Economics and Finance. Professor Schmittlein also didn’t deny that the ideal candidate for the PhD programs in Economics and Finance has strong Mathematics and Statistics knowledge and skills combined with a solid background in Economics. He also didn't deny that my non-underrepresented ENSAE Paris Tech graduate peers have the ideal backgrounds for the PhD programs in Economics and Finance. At the time, in 2019, about 10% of students of the PhD program in Finance of MIT were such peers. However, Professor Schmittlein implied that I have less knowledge and skills compared to my non-underrepresented ENSAE Paris Tech graduate peers because I am African American. So far, this racism of Professor Schmittlein against African Americans like me has been unlawfully backed by OCR investigators such as Michelle Kalka (Compliance Team Leader) and Gillian Thompson (Attorney) of OCR Office in Boston, MA.

Similarly, during the time affirmative action was still legal, I asked people of Harvard University the reason they denied me admission. The Dean for Admission and Financial Aid, Mohan D. Boodram, responded by saying the following, I quote, “The Program in Business Economics is one of the most selective in the Graduate School. Each year it receives applications from many more students than it can possibly accept. Indeed, overall the Graduate School is only able to admit 6% of those who apply. In this very competitive environment, the decision to approve or deny admission is a complex one and does not rest on any single factor. The goal of the admissions committee is to select those applicants whose academic background and interests most strongly suggest a successful and mutually productive graduate career". In other words, Mohan D. Boodram and his fellow admission staff didn’t deny that the ideal candidate for the PhD program in Business Economics is an applicant with strong academic background in all the 3 fields Mathematics, Statistics, and Economics; and they didn’t deny that I possess that ideal academic backgrounds for the PhD program in Business Economics. They also didn’t deny that the academic background and interests of my non-underrepresented ENSAE Paris Tech graduate peers strongly suggest a successful and mutually productive graduate career (the PhD program in Business Economics of Harvard University does even import and sponsor foreign Professors that are my non-underrepresented ENSAE Paris Tech graduate peers such as Professor Stefanie Stantcheva (ENSAE Paris Tech alumna, class of 2009) and Professor Vincent Pons(ENSAE Paris Tech alumnus, class of 2006)). But Mohan D. Boodram and his fellow admission officers treat me differently compared to my non-underrepresented peers by saying/implying that my academic background and interests do not strongly suggest a successful and mutually productive graduate career. The unspoken reason why Harvard’s admission staff treat me differently compared to my non-underrepresented peers is the following: the graduates of the PhD program in Business Economics of Harvard University have high salary; you can check the case of Anastassia Fedyk who got her PhD in Business Economics from Harvard University in 2018, her entry level compensation as an Assistant Professor of Finance at University of California - Berkeley was $338,716 per year (see here); and Harvard’s PhD admission staff don’t want Blacks/African Americans like me to get such high paying jobs. That’s why Harvard University didn’t let me to submit an application for graduate/PhD admission anymore. Similarly, federal government employees with 4 SOA/CAS actuarial certification exams are paygrade 12 above PhDs in Economics/Finance/Actuarial Science; I have already passed more than 4 SOA/CAS actuarial certification exams and these 4 or more SOA/CAS actuarial certifications do already constitute a preferred qualification for the Professor of Actuarial Science jobs (see my statement of purpose here ); but Mohan D. Boodram implied that these indisputable proofs of skills of mine "don’t strongly suggest" a successful and mutually productive graduate career; Mohan D. Boodram suggested/implied that I should throw to the garbage my SOA/CAS actuarial certification exams. And adding insult to injury, so far the racism and discrimination of Harvard University's PhD programs against qualified Blacks/African Americans like me has always been unlawfully backed by investigators of the OCR Office in Boston, MA.

Similarly, when Professor Persis Drell was Provost of Stanford University, she also didn’t deny that her university routinely admits my non-underrepresented ENSAE Paris Tech graduate peers. i.e. She didn’t deny that my non-underrepresented ENSAE Paris Tech graduate peers are qualified and/or competitive for the graduate/PhD programs in Statistics, Economics, and Finance of Stanford University. For example, currently there are non-underrepresented ENSAE Paris Tech graduates (such as Alex Tordjman, Eva Lestant, Ava Kouhana, Julien Maire, etc.) that are studying and/or doing research at Stanford University. However, Professor Drell alleged that, unlike my non-underrepresented ENSAE Paris Tech graduate peers, I am not qualified nor competitive for the graduate/PhD programs in Statistics, Economics, and Finance of Stanford University. The unspoken reason she considered me to be not qualified and/or not competitive is because of my race and/or origin. It’s also worth noting that the racism of Professor Persis Drell is not the mere occurrence of isolated or accidental or sporadic discriminatory act: it’s the regular admission practice of Stanford University vis-à-vis Blacks/African Americans that seek admission to graduate/PhD programs. In other words, there is no indication Stanford’s graduate/PhD admission discrimination against Blacks/African Americans will end. For instance, the dean of Stanford Graduate School of Business (Professor Jonathan Levin) will be Stanford University's 13th president starting the Aug. 1, 2024: Professor Jonathan Levin is an Economist; i.e. he knows that, with my academic backgrounds in 3 fields Mathematics/Statistics/Economics, I am an ideal candidate for his PhD programs in Economics and Finance; but he backs his admission officers denying me admission and preferring admitting less qualified non-underrepresented applicants who are far from an ideal candidate. And these racism and discrimination of Professors of Stanford University against Blacks/African Americans like me have been indirectly backed by investigators of OCR Office in San Francisco, CA.

Similarly, the website for Northwestern University’s Finance PhD program says “What We Are Looking for in Applicants? We seek students with strong training in mathematics and statistics and a solid background in economics” (see here). Which I indeed have. However, Professor Francesca Cornelli, the Business School Dean and Finance Chair, supported denying me admission and preferring admitting less qualified (younger) non-underrepresented applicants who majored in only Economics. For instance, at the time I first checked the backgrounds of the applicants admitted to the PhD program in Finance of Northwestern University, the admission staff admitted Tim Seida, Junko Oguri, Yudan Ying and Tongtong Yao; and all these younger, non-underrepresented applicants did major in only Economics but not Mathematics nor Statistics. It’s also worth noting that the Provost of Northwestern University (Professor Kathleen Hagerty) and/or the President of Northwestern University do all seem to back and/or condone the admission practice against qualified Blacks/African Americans like me. The discrimination has also been indirectly backed by investigators of OCR Office in Chicago, IL.

Similarly, when I sought admission to the PhD programs in Statistics, Economics and Finance of Tepper School of Business of Carnegie Mellon University, they also denied me admission. I then asked to directly sitting for and passing the PhD qualifying examination of the PhD programs in Economics and Finance. In fact, people say the PhD qualifying examination is a merit-based examination. I have always excelled in merit-based examinations; so, I asked to directly sit for and pass the PhD qualifying examination. My proposition is not a request for a favor. On the contrary, my proposition is a merit-based method to get one of the best candidates, me. In other words, I proposed to raise the bar for myself. However, Professor Robert Dammon, Dean of Carnegie Mellon University’s Tepper School of Business in 2019, said that getting around the screening process is “unfair” to the non-underrepresented applicants. In other words, Professor Robert Dammon implied that the “fairness” is the current practice of PhD admission staff where qualified Blacks/African Americans like me are systemically rejected during the screening process. This racism/discrimination against Blacks/African Americans like me has been indirectly backed by investigators of OCR Office in Philadelphia, PA.

Similarly, when I sought admission to the PhD program in Economics of Ohio State University for Fall 2007 admission, the then Director of Graduate Studies, Professor Hajime Miyazaki, sent me an email acknowledging that my academic backgrounds (combined BS/MS with triple major in Mathematics, Statistics, and Economics) were well suited for the PhD study in Economics. However, when his admission staff saw my race/origin, they rescinded my qualification by alleging that my GRE Verbal score was “low”. More precisely, they admitted non-underrepresented applicants with lower GRE Verbal score than mine, but they considered my GRE Verbal score to be “low” for an applicant of my race/origin. They said/implied this: they won’t admit me as long as they still have qualified candidates from other race/origin, even though those candidates are not ideal candidates for the PhD program in Economics.

Furthermore, it’s also worth noting that, before entering the “Statistician and Economist Engineer” training program, I did already take up to 2nd year PhD courses of PhD programs in Mathematics such as Theory of Groups/Rings/Fields (Abstract/Modern Algebra Theory), Theory of Topology, Theory of Measure & Integration, Measure-based Theory of Probability , Functional Analysis (analysis in Hilbert spaces and in Banach spaces), Distribution Theory (generalized functions theory), etc. Also, during my study in the “Statistician and Economist Engineer” program, I also had up to 2nd year PhD courses in Mathematics. You can check here and/or here, ENSAE Paris Tech does even co-organize a PhD program in Mathematics of Insurance, Economics and Finance (MASEF) and some of the 2nd year and 3rd year courses of ENSAE Paris Tech are part of the PhD program in MASEF (The current Dean of Tepper School of Business of Carnegie Mellon University, Professor Isabelle Bajeux-Besnainou, is an example of the graduates of the PhD program in MASEF co-organized by ENSAE Paris Tech). With these Math PhD course backgrounds, I can directly pass PhD qualifying examination of any PhD programs in Mathematics. Similarly, during the “Statistician and Economist Engineer” study, I did also take up to 2nd year PhD courses of PhD programs in Statistics such as Theory of Measure and Integration, Measure-based Theory of Probability, Theory of Mathematical Statistics 1 & 2, Bayesian Statistics Theory, Theory of Non-Parametric Estimation and Testing, Econometrics Theory 1 & 2, Advanced econometrics Theory: Panel data and duration models, Statistical Methods of Econometrics, Linear Time Series Theory, etc.; and with these courses, I can directly pass PhD qualifying examination of any PhD programs in Statistics. Similarly, the 4 or more actuarial certification exams I passed do already encompass all the core courses of the PhD programs in Actuarial Science (see the core PhD courses in Actuarial Science here or here); thus, I can directly pass PhD qualifying examination of any PhD programs in Actuarial Science too. So, not only did I ask to directly pass the PhD qualifying examinations of PhD programs in Economics and Finance, but I did also ask to directly sit for and pass PhD qualifying examinations of 3 other groups of PhD programs (PhD programs in Mathematics, PhD programs in Statistics, and PhD programs in Actuarial Science) at many U.S. universities such as Harvard (PhD program in Statistics), Yale (PhD program in Statistics), UConnecticut-Storrs (PhD program in Mathematics/Actuarial Science), Cornell (PhD program in Statistics), Columbia (PhD program in Statistics), NYU (PhD program in Statistics), Princeton (PhD program in Mathematics/Financial Engineering), UPenn (PhD program in Statistics), PennState (PhD program in Statistics), Carnegie Melon (PhD program in Statistics), UChicago (PhD program in Statistics; PhD program in Statistics and Econometrics), UW-Madison (PhD program in Economics/Actuarial Science), UW-Milwaukee (PhD program in Mathematics/Actuarial Science), UIowa-Iowa City (PhD program in Statistics/Actuarial Science), UIllinois-Urbana Champaign (PhD program in Statistics; PhD program in Mathematics/Actuarial Science), Stanford (PhD program in Statistics), UC-Berkeley (PhD program in Statistics), and UC-Santa Barbara (PhD program in Probability/Actuarial Science), etc. All these universities denied my request to directly sit for their PhD qualifying examinations despite the fact their policy allows a non-matriculated student like me to directly sit for their PhD qualifying exams, and despite the fact these universities say they don't find qualified African Americans to do PhD studies.

Also, after I requested to directly pass qualifying examinations for the PhD programs I sought, OCR investigators abandoned their allegation of my lack of knowledge and skills for PhD study. But they still directly and/or indirectly supported admissions staff denying me admission. In fact, I kept applying for admission to PhD programs of a couple of top-ranking universities such as MIT, Harvard, Yale, Columbia, UPenn, UChicago, Northwestern, Stanford, and UC-Berkeley; and the admission staff kept denying me admission. When I filed discrimination complaint with OCR, the OCR investigators knowingly, intentionally, and willfully violated their legal standard and misused their Case Processing Manual (CPM) by wrongfully alleging that there is not sufficient fact to infer that discrimination or retaliation may have occurred or is occurring. i.e. They wrongfully used the Section 108(d) of their CPM of 2022 and/or Section 108(b) of their CPM of 2020. Then they directly dismissed my complaint without investigating and without asking the admission staff to respond to my charge. OCR investigators probably expected me to give up, but I didn’t. In fact, according to their CPM, the complaint dismissed for insufficiency of information can be refiled again. See for example the page 10 of their CPM of 2020 that says, I quote, “Complainants may elect to refile complaints that were dismissed pursuant to CPM Sections… 108(b)… if they have addressed the deficiencies stated by OCR in the dismissal; such refiled complaints will not be dismissed pursuant to CPM Section 108(m)”. So, I kept applying for PhD admission; the admission staff kept denying me admission; then I addressed the alleged deficiency stated by OCR investigators and I refiled my complaint. Then, running out of pretext to dismiss my complaint, OCR investigators made false statement by alleging that my complaint had already been found to be without merit by OCR. They then wrongfully dismiss again my complaint by misusing the Section 108(m) of their CPM of 2020 and/or by misusing the Section 110(i) on page 13 of their CPM of 2022.

Besides, it's also worth noting that when I first filed a discrimination complaint with OCR in 2007, the OCR acknowledged that an applicant for PhD programs in the USA does not need to apply more than three times. Because if they aren’t accepted by then, they are either not qualified or have been discriminated against by admissions staff. For a third time, I applied in 2007 for Economics and Finance PhD programs to University of Maryland-College Park and to a couple of top ranking universities such as MIT, Harvard, Yale, Columbia, UPenn and UC-Berkeley. When I first filed a discrimination complaint with OCR that year 2007, OCR said I was not qualified (They alleged that I didn’t have enough Mathematics and Economics knowledge and skills for the PhD study in Economics and Finance). However, since I asked to directly pass PhD qualifying examinations of 5 PhD programs (PhD program in Mathematics, PhD program in Statistics, PhD program in Economics, PhD program in Finance, and PhD program in Actuarial Science), OCR retracted their allegation of my lack of academic knowledge and skills for PhD studies. i.e. OCR implicitly acknowledged that I am not unqualified for the PhD programs in Economics and Finance. Thus, if I am not unqualified, I have been discriminated against by admissions staff, pursuant to the above-mentioned practice for PhD application in USA. Unfortunately, instead of condemning and/or stopping the discrimination against me, OCR investigators still knowingly, intentionally, willfully back and/or ignore the admission staff’s PhD admission discrimination practice against me.

5 . The statistics of National Science Foundation do also corroborate the wide-spread PhD admission discrimination against Blacks/African Americans like me

During the last 20 years period, I have been seeking admission to more than 60 PhD programs of top 100 universities in USA; and all of them denied me admission despite my qualification. Thus, the different treatment against Blacks/African Americans like me is not the mere occurrence of isolated or accidental or sporadic discriminatory acts. Rather, the different treatment against Blacks/African Americans like me is the admission staff’s regular practice. i.e. The racism/discrimination against Blacks/African Americans like me is rampant in US universities. The statistics of National Science Foundation (NSF) corroborate this fact.

In fact, Blacks/African Americans represent around 12% of American population. However, according to NSF data, each year, only 1.5% of new PhD graduates in Mathematics and Statistics and only 2% of new PhD graduates in Economics and Finance from US universities are Blacks/African Americans despite the fact there are thousands of qualified Blacks/African Americans like me who want to do PhD studies in these fields. In International Brotherhood of Teamsters v. United States, 431 U.S. 324 (1977), the Court stated that “statistics showing racial or ethnic imbalance are probative … because such imbalance is often a telltale sign of purposeful discrimination”. In the Hazelwood Sch. Dist. v. United States, 433 U.S. 299, 307–08 (1977), the Court also said that “Where gross statistical disparities can be shown, they alone may in a proper case constitute prima facie proof of a pattern or practice of discrimination”. Accordingly, the 1.5% - 2% of Black/African American PhD representation do already speak for themselves for the PhD admission discrimination against Blacks/African Americans: there is a wide-spread discrimination against Blacks/African Americans for access to PhD programs in Mathematics, Statistics, Economics, Finance, and Actuarial Science. Unfortunately, such systemic discrimination against Blacks/African Americans has always been wrongfully backed by OCR investigators. If the admission staff and the OCR investigators abstained from discriminating against Blacks/African Americans, the Black/African American representation in PhDs in these fields would probably rise ten times higher or more.

6 . The PhD admission discrimination practice against Blacks/African Americans is also corroborated by findings of academic researchers

Let’s take the case of the research findings of Professor Julia Posselt in her book titled “Inside Graduate Admissions: Merit, Diversity, and Faculty Gatekeeping ” published by Harvard University Press in 2016. Professor Posselt is a professor of higher education in the USC Rossier School of Education of University of Southern California. “How does graduate admissions work? Who does the system work for, and who falls through its cracks?... Drawing on firsthand observations of admission committees and interviews with faculty in 10 top-ranked doctoral programs in the humanities, social sciences, and natural sciences, education professor Julie Posselt pulls back the curtain on a process usually conducted in secret” said Harvard University Press about the book. The pages 76-78 of Chapter 3 of the book are devoted exclusively to the admission to PhD programs in Economics.

In summarizing the findings of Professor Posselt, Harvard University Press says, I quote, “Inside Graduate Admissions presents admissions from decision makers’ point of view.... Who ultimately makes the admit list reveals as much about how Professors see themselves — and each other — as it does about how they view students. Professors in these programs say that they admit on merit, but they act on different meanings of the term”. I am a living proof of the veracity of the findings of Professor Posselt. In fact, I have always excelled in merit-based examination: I got an ETS recognition of excellence award in Mathematics, a merit-based standardized examination indicating I am among the top 15% best BS in Math holders in USA; I got admitted to the “Statistician and Economist Engineer” training program of ENSAE Paris Tech, another merit-based standardized written examination indicating I am among the top 1% best BS/MS in Math/Statistics/Economics; I succeeded to pass SOA/CAS actuarial certification exams, another merit-based standardized examination indisputably proving my strong knowledge and skills in quantitative fields, etc. But when I apply for admission to PhD programs in Mathematics, Statistics, Economics, Finance and Actuarial Science, the admission staff say I don’t merit to be admitted: admission staff say/imply that my non-underrepresented ENSAE Paris Tech graduate peers merit to get admitted to PhD programs of their choices but not a Black/African American like me; admission staff also say/imply that non-ideal (less qualified) non-underrepresented applicants who major in only Economics or Mathematics merit to get admitted to PhD programs in Economics and Finance but not a Black/African American ideal candidate (better qualified) like me; and in the eyes of the admission staff, non-underrepresented applicants with less SOA/CAS actuarial certification exams merit to get admitted, but not a Black/African American applicant like me with more SOA/CAS actuarial certification exams, etc. These facts speak for themselves for the racism and discrimination against Blacks/African Americans like me for access to PhD programs in Mathematics, Statistics, Economics, Finance, and Actuarial Science.

Furthermore, given my journey and Professor Posselt's findings, it’s clear the PhD admissions process can be divided into two phases. The first phase is the screenings of the applicants. Affirmative Action, when it was legal, was not yet applied during the screenings; and qualified Black/African American applicants like me have been systemically rejected during those screenings, regardless of qualification. Harvard University Press acknowledges this admission practice against underrepresented Blacks/African Americans by saying, I quote, "Who ultimately makes the admit list reveals as much about how Professors see themselves — and each other — as it does about how they view students. Professors in these programs say that they admit on merit, but they act on different meanings of the term". Apparently, only the few Black/African American applicants who can camouflage their “blackness” and origin during the screenings do succeed to reach the next phase of the admission process. The second phase of the PhD admission process is for the admission decisions. However, even when Affirmative Action was supposed to be applied then, discrimination still occurred. “Professors also say that they seek diversity, but Posselt shows that their good intentions don’t translate into results. In fact, faculty weigh diversity in only a small fraction of admissions decisions. Often, they rely upon criteria that keep longstanding inequalities in place”, Harvard University Press says. To sum up, even when the Affirmative Action was still legal, it didn’t prevent the admission officers from discriminating against Blacks/African Americans. i.e. Contrary to popular belief, Black/African American PhD applicants as a whole have never benefited from the Affirmative Action policy. The opposite seems to be true: non-underrepresented minority PhD applicants and non-underrepresented majority PhD applicants have always benefited from the admission practice of admission staff in the sense the spots supposed to be for qualified Blacks/African Americans like me have always been given to less qualified non-underrepresented minority PhD applicants and/or to less qualified non-underrepresented majority PhD applicants; and the admission discrimination practice against Blacks/African Americans was camouflaged by the flaunting of Affirmative Action policy. That's why only 1.5% of new PhD graduates in Mathematics and Statistics and only 2% of new PhD graduates in Economics and Finance are Blacks/African Americans despite the fact there are thousands of qualified Blacks/African Americans that can rise the Black representation statistics to ten times higher or more.

Let’s take the case of Harvard University that was a well known Affirmative Action university. Many Americans, including Justices of the United States Supreme Courts, wrongly believe that Blacks/African Americans who applied for admission to PhD programs of Harvard University benefited from the Affirmative Action policy and non-underrepresented minority PhD applicants were hurt by the Affirmative Action policy. However, the facts prove those people are misinformed, if not disinformed. For instance, if you look at the profile of applicants admitted each year to the PhD programs in Economics of Harvard University, they clearly show that the PhD programs have always preferred admitting less qualified non-underrepresented minority applicants rather than admitting Black/African American ideal candidates like me. For example, this year 2023, the PhD programs in Economics of Harvard University admitted non-underrepresented minority applicants Carissa Chen, Catherine Huang, Baiyun Jing, Jiaxuan Lu, Steven Ma, Eu-Wayne Mok, Cathy Wang, Nan Xiang, Xinmei Yang, and Yixin Zhou, etc.: none of them was an ideal candidate for the PhD programs in Economics; the majority of them did major in only Economics (Carissa Chen, Catherine Huang, Jiaxuan Lu, Eu-Wayne Mok, Cathy Wang, Nan Xiang, etc.); but admission staff of Harvard University did prefer admitting them rather than admitting a Black/African American ideal candidate like me. I can directly pass PhD qualifying examination and finish the PhD study in 3 to 4 years, but Harvard University preferred admitting non-underrepresented minority candidates who can't finish their PhD study in 5 years such as Yihong Huang, Yixi Jiang, Edward Kong, Ziqi Lu and Angela Ma. More generally, people who graduate from "grandes ecoles" are the very brightest students their generation has to offer; but PhD admission staff of Harvard University treat Blacks/African Americans like me differently because of our race/origin: the admission staff say/imply that, unlike academic backgrounds and interests of our non-underrepresented ENSAE Paris Tech graduate peers, the academic background and interests of Blacks/African Americans like me "do not strongly suggest a successful and mutually productive graduate career". And this PhD admission discrimination practice of its admission staff against underrepresented Blacks/African Americans like me has been acknowledged by Harvard University itself: "Professors in these programs say that they admit on merit, but they act on different meanings of the term" said Harvard University Press. It’s how PhD admission staff of affirmative action universities such as Harvard University treated Blacks/African Americans during the time affirmative action was legal: it's not the underrepresented Black/African American PhD applicants that benefited from the Affirmative Action policy but the non-underrepresented minority PhD applicants and the non-underrepresented majority applicants in the sense the flaunting of the Affirmative Action policy did camouflage the graduate/PhD admission discrimination against Blacks/African Americans like me. In other words, it's not the non-underrepresented minority PhD applicants but the underrepresented Black/African American PhD applicants that have been held to higher standards than everyone else. It's also not the mere occurrence of isolated or accidental or sporadic discriminatory acts, but the admission staff’s regular admission practice against Blacks/African Americans. Thus, saying that Black/African American PhD applicants benefited from the Affirmative Action policy is an aggravated aggression against Blacks/African Americans, if not a hate speech.

I am also going to take this opportunity to address the lie and disinformation spread by “Students for Fair Admission” organization about an alleged race based graduate/PhD admissions that Blacks/African Americans benefit from. In fact, the organization directly and/or indirectly alleges that Blacks/African Americans have been held to a lower standard when it comes to the access to graduate/PhD programs. On page 65 of its lawsuit against Harvard University in 2014, the organization said, I quote, “The “model minority” stereotype of high-achieving Asian Americans does an even greater disservice to socioeconomically disadvantaged individuals by making it virtually impossible for disadvantaged Asian Americans to compete with disadvantaged students from other races who are held to a lower standard”. However, the facts prove that the discriminated against are not the non-underrepresented minority PhD applicants but the underrepresented Black/African American PhD applicants: when it comes to the access to graduate/PhD programs in Mathematics, Statistics, Economics, Finance and Actuarial Science of top ranking universities such as Harvard University and Princeton University, it’s virtually impossible for disadvantaged Blacks/African Americans like me to compete with the students from both non-underrepresented minority race and non-underrepresented majority race.

Let’s take the example “Students for Fair Admission” organization took on page 65 of its lawsuit against Harvard University. It says, I quote, “For example, Kai Chan, a Princeton doctoral student in economics and the son of Chinese immigrants, describes the struggles he has endured: “Is it fair in the name of (skin-deep) diversity to hold back qualified students from admission to the Ivies because of their race? After all, it is a fact that Asians need higher academic achievements than their peers to get admitted to the same school…. The misguided approach of programs like affirmative action can be seen through my experience. I am the son of poor, non-English speaking parents, neither of whom attended high school. They never read to me as a child. They never attended my graduations. I went to some terrible high schools. (Altogether, I attended five high schools, one of which was known locally as ‘last chance high.’) I worked practically full-time while attending high school and college. But I’ve never gotten the benefit of the doubt anytime in my life. If anything, I’ve had to be better than my peers””. Contrary to what the Canadian Kai Chan suggests and the “Students for Fair Admission" organization insinuates, this case of Kai Chan does not show that the non-underrepresented minority PhD applicants like Kai Chan were at a disadvantage. The opposite is true: this case of Kai Chan does prove that the non-underrepresented minority PhD applicants like Kai Chan are preferred and the underrepresented Blacks/African Americans like me are discriminated against. In fact, I am son of poor (almost illiterate) Black parents from rural area; I was 6 years old and my 5 siblings were between 3 months old and 16 years old when our father passed away; so, basically I grew up in a poor mono-parental family and I started working at a very young age to help the family making a living; we had never benefited from government assistances, etc... But because of my hard work, the situation didn’t prevent me from excelling in my studies. In particular, I succeeded to pass the rigorous, merit-based, standardized written international Math competition examination for access to the “Statistician and Economist Engineer” honors program of ENSAE Paris Tech where I graduated with combined BS/MS honors degree with triple major in Mathematics, Statistics, and Economics. With these academic backgrounds of mine, I was an ideal candidate for the PhD program in Economics and Finance of Princeton University whereas Kai Chan was not (He graduated with only Bachelor degree with double major in Mathematics and Economics from University of Toronto (see his CV here )). i.e. I was better qualified than Kai Chan for the PhD program and research career in Economics and Finance, but admission officers of Princeton University preferred admitting less qualified non-underrepresented minority applicants like Kai Chan rather than admitting the better qualified underrepresented Black/African American applicants like me. For those of you who are familiar with academic courses in Mathematics, you can check here the list of undergraduate courses in Mathematics of University of Toronto: Kai Chan had only a BS degree in Mathematics; so, at the time he got admitted to Princeton University’s PhD program in Economics, he couldn’t even pass the Math exams for access to "grandes ecoles" of Economics and Statistics (my Math exams for access to the "Statistician and Economist Engineer" program of ENSAE Paris Tech and the Math exams for access to the "Statistician Engineer" program of ENSAI(see the last paragraph of the current Chapter)). Also, Princeton University was an affirmative action university and I was an underrepresented African American; but despite the affirmative action policy and my better qualification, admission staff of Princeton University didn’t admit me; they preferred admitting less qualified non-underrepresented applicants like Kai Chan. Similarly, there are more than 200 Black folks of different nationalities who graduate each year from the “Statistician and Economist Engineer” program of ENSAE Paris Tech and from the “Statistician Engineer” program of ENSAI (see the last paragraph of the current Chapter): those graduates of “grandes ecoles" of Statistics and Economics do all have triple academic backgrounds in Mathematics, Statistics, and Economics; therefore, they are all ideal candidates (best qualified candidates) for the PhD programs and research careers in Statistics, Economics, Finance and Actuarial Science; but US universities such as Princeton University always reject them and prefer admitting non-underrepresented minority applicants like Kai Chan who are not ideal candidates. In other words, many of the non-underrepresented minority applicants admitted to top ranking PhD programs in Economics and Finance (if not the majority of non-underrepresented minority applicants admitted to top-ranking PhD programs in Economics and Finance) do not merit to get admitted; they just benefit from the exclusion of qualified Black/African American PhD applicants like me (the graduate/PhD admission is a zero-sum game; the rejection of better qualified Blacks/African Americans like me benefit less qualified non-underrepresented applicants like Kai Chan).

Similarly, many non-underrepresented minority applicants behind the “Students for Fair Admission” organization’s lawsuit against Harvard University (if not the majority of non-underrepresented minority applicants behind the “Students for Fair Admission” organization’s lawsuit against Harvard University) are sons and/or daughters of first-generation immigrants who benefited from the graduate/PhD admission discrimination against Blacks/African Americans. i.e. Without the graduate/PhD admission discrimination against Blacks/African Americans, their parents could not have been admitted to graduate/PhD programs in USA and they could not have lived here in USA (I recall that the graduate/PhD admission is a zero-sum game; the rejection of better qualified Blacks/African Americans benefit less qualified non-underrepresented applicants). Let’s take the case of Jeff Wang, the father of Michael Wang (Michael Wang was one of the non-underrepresented minority students behind the “Students for Fair Admission” organization’s lawsuit against Harvard University). Jeff Wang is first-generation immigrant. He was not an ideal candidate for his graduate/PhD program; in particular, he was less qualified than Black/African American PhD applicants who graduated from “grandes ecoles”; but the admission staff preferred admitting the non-underrepresented minority applicant Jeff Wang rather than admitting the better qualified underrepresented Black/African American candidates such as Black/African American PhD applicants graduates of "grandes ecoles". In other words, Jeff Wang was not admitted by merit; he got admitted because of the existence of the graduate/PhD admission discrimination practice against Blacks/African Americans. Let's take another example of students behind “Students for Fair Admission” organization’s lawsuit against Harvard University: the case of Jon Wang (no relation to Jeff Wang). Jon Wang's parent is first generation immigrant to USA too; and like Michael Wang’s father, the parent of Jon Wang got admitted not by merit but because of the graduate/PhD admission discrimination against Blacks/African Americans too. Therefore, these students behind “Students for Fair Admission” organization’s lawsuit against Harvard University are not under-privileged but privileged students who could thrive thanks to racism and discrimination against Blacks/African Americans. More generally, as Harvard University Press says, I quote, “Who ultimately makes the admit list reveals as much about how Professors see themselves — and each other — as it does about how they view students. Professors in these programs say that they admit on merit, but they act on different meanings of the term”, the existence of the affirmative action policy didn’t prevent the (non-underrepresented) admission Professors from preferring less qualified non-underrepresented applicants and rejecting better qualified underrepresented Blacks/African Americans. Thus, saying non-underrepresented minority PhD applicants have been discriminated against is an aggravated aggression against Blacks/African Americans like me who are the true victim of graduate/PhD admission discrimination practice in USA.

Let’s take another example of lie and disinformation spread by “Students for Fair Admission” organization: an article about an alleged admission discrimination practice against non-underrepresented minority applicants by PhD programs in Economics of Harvard University. The article was initially written by Chris Brunet of the Post Millennial the May 08, 2023 (see here) and republished by the web site of “Students for Fair Admission” organization (see here). In the article Chris Brunet says, I quote, "The Harvard Crimson reported on an incident in 2017 where confidential data about admitted PhD students were accidentally emailed to every student in the economics department… This leak comes at a crucial time, as the Supreme Court of the United States prepares to repeal affirmative action. The lawsuit that led to this decision was based on evidence of discriminatory practices at Harvard, specifically against Asian students in undergraduate admissions. While today’s newly leaked data deals with graduate admissions, instead of undergraduate admissions, the principle remains the same: Harvard is discriminating against Asians". It’s another lie and disinformation too. In fact, there is no such thing as Harvard’s graduate/PhD admission discrimination against non-underrepresented minority applicants. The facts Chris Brunet referred to, as you can see above, do not indicate graduate/PhD admission discrimination against non-underrepresented minority applicants; instead, those facts clearly indicate the racism and discrimination against Blacks/African Americans like me. In fact, the author said, I quote, "There were 44 students admitted to the Harvard economics department's PhD program in 2017, of which 3 (7 percent of the cohort) were classified as "Minority" and 8 (18 percent of the cohort) as "Lobby." It should be noted that roughly a dozen of the admitted applicants were Asian, but none of those were tagged as “Minority”... In addition to the hidden minority flag column, there was also a hidden column showing internal discussions about the admitted PhD students. The vast majority of these comments about the 44 admitted students are positive; the 2 harshest comments were reserved for the only 2 “Minority” admits who actually matriculated to Harvard. Both of them were Latino males.... It seems that “Minority” candidates got accepted despite negative reviews". I personally checked the academic backgrounds of the non-underrepresented applicants admitted that year in 2017: virtually none of them were an ideal candidate for the PhD programs and research careers in Economics and Finance; therefore, they were less qualified than the Black/African American ideal candidates like me; but Harvard's admission staff gave those non-underrepresented applicants positive review and admitted them whereas the better qualified Black/African American ideal candidates like me have always been given negative review and denied admission. Thus, the admission practice of the PhD programs in Economics of Harvard University is a racism against Blacks/African Americans like me, but not a discrimination against non-underrepresented minority applicants nor a discrimination against non-underrepresented majority applicants. I recall that, with my combined BS/MS honors degree with triple major in Mathematics/Statistics/Economics, I am an ideal candidate for the PhD programs and research careers in Economics and Finance; but admission staff of Harvard University said/implied that my academic background and interests "don't strongly suggest" a successful and mutually productive graduate/PhD career (they imply that only the academic background and interests of my non-underrepresented peers do strongly suggest a successful and mutually productive graduate/PhD career). And Harvard University Press has acknowledged this unequal treatment against Blacks/African Americans by saying, I quote, "Professors in these programs say that they admit on merit, but they act on different meanings of the term". Similarly, the admission of the 2 Latino minority applicants cited in the above-mentioned article does not indicate a discrimination against non-underrepresented applicants too. If the admission of the 2 Latino applicants is really a discrimination, it’s not a discrimination against non-underrepresented applicants who are not ideal candidate, but a discrimination against Black/African American ideal candidates like me.

Furthermore, “Students for Fair Admission” organization acknowledges that only top ranking universities, such as Ivy league universities, "discriminate" against the non-underrepresented minority persons. i.e. “Students for Fair Admission” organization acknowledges that the non-underrepresented minority applicants that are "discriminated against" by top ranking universities can get admission elsewhere at lower ranking universities. The case of Blacks/African Americans is far worse than that: not only are the Blacks/African Americans like me discriminated against by graduate/PhD programs of top ranking universities, but they are also discriminated against by virtually all graduate/PhD programs of US universities from east coast to west coast. I am a living proof of this fact: during the last 20 years period, I submitted more than 100 applications for admission to graduate/PhD programs of US universities from east coast to west coast (giving an average of about 5 applications per year during 20 years straight); but all the admission staff denied me admission despite me being an ideal candidate, whereas they admitted less qualified non-underrepresented applicants. In other words, the graduate/PhD admission discrimination against Blacks/African Americans like me is not the mere occurrence of isolated or accidental or sporadic admission discrimination acts of a couple of universities, but the regular admission practice of virtually all US universities. “Students for Fair Admission” says the organization was formed, I quote, “for the purpose of defending human and civil rights secured by law, including the right of individuals to equal protection under the law... More specifically, SFFA seeks to promote and protect the right of the public to be free from discrimination on the basis of race in higher education admissions". However, in my knowledge, “Students for Fair Admission” has never raised its voice against the above-mentioned systemic graduate/PhD admission discrimination against Blacks/African Americans. That’s why the name “Students for Fair Admission” is misleading and the organization is hypocrite. One of the most appropriate names for the organization is “Students for Racism and Unfair Admission against Blacks/African Americans”.

It's also worth noting that there are more than 100 Blacks of different nationalities that graduate each year from the “Statistician and Economist Engineer” training program of ENSAE Paris Tech. The majority of them (if not almost the totality of them) want to do PhD study in USA, but they face the unsurmountable racism of admission officers against Blacks. Besides, there is another “grande ecole” of Economics and Statistics called “ENSAI” with its honors training called “Engineer Statistician” program. You can find here and/or here a sample of the merit-based, standardized written Math competition examination for access to the "Engineer Statistician" program of ENSAI. The ENSAI and the ENSAE Paris Tech combined are called group of “grandes ecoles” of Economics and Statistics or “GENES”; and their research center is called Center for Research in Economics and Statistics (CREST) (see here and/or here). ENSAI is a tier 2 “grande ecole”: it's less prestigious than the tier 1 "grande ecole" ENSAE Paris Tech (the Math competition examination for access to ENSAI is less difficult compared to the Math competition examination for access to ENSAE Paris Tech ; and the coursework of the "Engineer Statistcian" training program of ENSAI are less challenging compared to the coursework of the "Statistician and Economist Engineer" training program of ENSAE Paris Tech); but the "Engineer Statistician" training program of ENSAI is still more competitive than the honors programs of universities. On top of that, during the 2 first years classes of the "Engineer Statistician" training of ENSAI, students are given B.S. honors training with triple major in Mathematics, Statistics, and Economics. So, with the BS with triple major in Mathematics, Statistics, and Economics backgrounds, the graduates of the "Engineer Statistician" program of ENSAI are also ideal candidates (competitive) for PhD studies and research careers in Statistics, Economics, Finance, and Actuarial Science. For instance, the graduates of the "Statistician Engineer" program of ENSAI are better qualified for the PhD program in Economics and Finance of Princeton University compared to Kai Chan who graduated with just a BS with double major in Mathematics and Economics from University of Toronto. There are more than 100 Blacks of different nationalities that graduate each year from the "Engineer Statistician" program of ENSAI; but virtually all of them face rejection too when they apply for admission to PhD programs in USA. By contrast, the non-underrepresented ENSAI graduates get easily admitted to PhD programs of their choice in USA. For example, I know a non-underrepresented minority person from the ENSAI program that got admitted to the PhD program in Mathematics with thesis in Actuarial Science of University of Connecticut - Storrs: he didn't do the 3rd year class of the "Engineer Statistician" program of ENSAI; he just did the 1st year and the 2nd year classes; then he directly got an admission to the PhD program in Mathematics/Actuarial Science of University of Connecticut-Storrs and eventually finished his PhD study in just 4 years.

7 . Conspiracy to commit offense or to defraud United States (18 U.S. Code § 371): not only do OCR investigators back Admission staff preferring admitting less qualified non-underrepresented foreign applicants, but they also indirectly back universities preferring importing foreign Professors graduates of our schools rather than admitting and training qualified Blacks/African Americans like me to become College Professor

According to 42 U.S. Code § 1862s–5 (Programs to expand STEM opportunities), the United States should encourage full participation of individuals from underrepresented populations in STEM such as African Americans like me. Also, pursuant to 42 U.S. Code § 1885 (Congressional statement of findings and declaration of policy respecting equal opportunities in science and engineering):

(i) . It is in the national interest of the USA to promote the full use of human resources in science and engineering and to insure the full development and use of the scientific and engineering talents and skills of men and women, equally, of all ethnic, racial, and economic backgrounds; and

(ii) . It is the policy of the USA to encourage men and women of all ethnic, racial, and economic backgrounds to acquire skills in science, engineering, and mathematics, to have equal opportunity in education, training, and employment in scientific and engineering fields.

Unfortunately, instead of working for that national interest of USA, OCR investigators do work for foreign interests: not only do OCR investigators back universities to prefer admitting less qualified non-underrepresented foreign PhD applicants rather than admitting better qualified African Americans like me, but OCR investigators do also indirectly back U.S. universities to prefer importing and sponsoring non-underrepresented foreign Professors graduates of our schools rather than admitting and training equally skilled African Americans like me to become College Professor. In other words, the unspoken practice of admission staff and OCR investigators vis-a-vis qualified African Americans like me is this: non-underrepresented foreigners first rather than qualified African Americans.

In fact, according to a study published in 2022, about 80% of Professors with PhD in USA have been trained at the top 20% universities (see here). Each year, National Science Foundation (NSF) awarded hundreds of millions of dollars of grants (if not billions of dollars of grants) to those top 20% universities; the grants meant to boost the PhD participation of underrepresented minorities such as African Americans like me. For example, NSF created the Alliances for Graduate Education and the Professoriate (AGEP) grants aiming to increase the number of underrepresented minority faculty such as African American faculty (you can find here the list of universities that have already been awarded the grants). However, thanks to the support provided by OCR investigators to the PhD admission staff that exclude qualified Blacks/African Americans like me, the grants don’t boost the participation of underrepresented African American College Professors. Rather, it seems as though the grants encourage admission staff to keep excluding qualified Black/African American PhD applicants like me. In other words, the fact seems to indicate that the more the universities exclude qualified Black/African American PhD applicants like me, the more grants they receive from NSF. The NSF said/implied that it’s not the fault of NSF: there is a written agreement between NSF and OCR that gives only OCR the power to investigate discrimination; so, if the OCR doesn’t condemn the admission practice of the admission staff, NSF keeps awarding grants to the universities regardless of the admission discrimination practice of the admission staff against Blacks/African Americans. In other words, the federal government funds supposed to boost the number of African American College Professors have always been wasted thanks to support provided by OCR investigators to PhD admission officers that exclude qualified Black/African American PhD applicants.

Let’s take the case of UC-Berkeley to better illustrate this fact. “Let us alone” said people of the PhD program in Finance of Haas School of Business of UC-Berkeley when I asked them their “reason” for denying me admission. They mean/imply that the PhD programs in Economics and Finance of UC-Berkeley are not for a Black/African American like me despite the fact I am an ideal candidate and their admitted non-underrepresented foreign candidates like William Zhang are not. The Chair of the PhD program in Finance (Professor David Sraer, an ENSAE Paris Tech alumnus like me), the Dean of Haas School of Business (Professor Ann Harrison, a person who didn’t have enough Mathematics and Economics knowledge and skills for access to ENSAE Paris Tech) and the Executive Vice Chancellor and Provost of UC – Berkeley (Professor Benjamin Hermalin, an Economics and Finance Professor) do all know that an ENSAE Paris Tech graduate like me is qualified and competitive compared to the majority of the non-underrepresented foreign candidates they admit to the PhD programs in Economics and Finance. But these people in charge of the PhD programs in Economics and Finance of UC-Berkeley keep denying me admission because the investigators of the OCR Office in San Francisco, CA have always wrongfully backed the admission discrimination practice against qualified Blacks/African Americans like me. It’s also worth to mention that asking them to step down can’t stop the admission discrimination against Blacks/African Americans because the next person(s) in charge will keep excluding qualified Blacks/African Americans as long as the investigators of the OCR Office in San Francisco, CA continue to back the racism and discrimination against Blacks/African Americans. Consequently, NSF keeps showering UC – Berkeley with grants despite the fact UC – Berkeley routinely exclude qualified Blacks/African Americans like me from participating in PhD programs. For example, UC-Berkeley got the NSF grants #2014976, the NSF grants #1647273 and the NSF grants #1306747, etc. These grants meant to boost the number of African American College Professors. Unfortunately, these funds have always been wasted in the sense they encouraged UC-Berkeley’s admission staff to keep excluding qualified Blacks/African Americans like me from participating to PhD programs. OCR investigators are accomplice in wasting of these funds.

Let’s take another example, the case of foreign Professors that are ENSAE Paris Tech alumni (non-underrepresented persons). As I already mentioned earlier above, the graduates of the Statistician and Economist engineer Honors program of ENSAE Paris Tech are well suited for research careers in Statistics, Economics, Finance, and Actuarial Science. In particular, Economics and Finance Professors alumni of ENSAE Paris Tech are exceptionally competitive in research careers in Economics and Finance because of their additional expertise in Statistics and Data Science. Top-ranking U.S. Business Schools and top ranking Departments of Economics of U.S. universities do all massively import and/or sponsor foreign Professors of Economics and Finance that are ENSAE Paris Tech alumni. Let’s take the example of the recent hirings of Business Schools of UC-Berkeley, UCLA, Stanford, UChicago, Northwestern, Ohio State, UNC-Chapel Hill, Duke, Georgetown, UPenn, Princeton, Columbia, NYU, Cornell, Yale, Harvard, and MIT. The PhD program in Finance of UC – Berkeley has imported and sponsored Professor David Sraer (the current Chair of the PhD program in Finance of Haas School of Business of UC-Berkeley): he is ENSAE Paris Tech alumnus, class of 2003. Similarly, the PhD program in Finance of UCLA has imported and sponsored Professor Clemence Tricaud (ENSAE Paris Tech alumna, class of 2016), Professor Matthieu Gomez (ENSAE Paris Tech alumnus, class of 2011), Professor Valentin Haddad (ENSAE Paris Tech alumnus, class of 2008), and Professor Pierre-Olivier Weill (ENSAE Paris Tech alumnus, class of 1999). Similarly, the PhD programs in Economics and Finance of Stanford Business School has imported and sponsored Professor Adrien Auclert (ENSAE Paris Tech alumnus, class of 2009); the PhD programs in Economics and Finance of Booth School of Business of UChicago has imported and sponsored as a research fellow Dr Elio Nimier-David (ENSAE alumnus, class of 2018) and Professor Agathe Pernoud (ENSAE Paris Tech alumna, class of 2017); the PhD programs in Economics and Finance of Northwestern University has imported and sponsored Professor Nicolas Crouzet (ENSAE Paris Tech alumnus, class of 2008); the Fisher School of Business of Ohio State University has imported and sponsored Professor Victor Lyonnet (ENSAE Paris Tech alumnus, class of 2012); the Kenan-Flagler Business School of University of North Carolina – Chapel Hill has imported and sponsored Professor Aymeric Bellon (ENSAE Paris Tech alumnus, class of 2016); the Fuqua School of Business of Duke University has imported and sponsored Professor Arnaud Maurel (ENSAE Paris Tech alumnus, class of 2006); the McDonough School of Business of Georgetown University has imported and sponsored Professor Charly Porcher (ENSAE Paris Tech alumnus, class of 2006); the PhD program in Finance of Wharton Business School of UPenn has imported and sponsored Professor Chaojun Wang (ENSAE Paris Tech alumnus, class of 2012); the Bendheim Center for Finance of Princeton University has imported and sponsored Professor Pauline Carry (ENSAE Paris Tech alumna, class of 2018); the PhD program in Finance of Leonard Stern School of Business of NYU has imported and sponsored Professor Edouard Schaal (ENSAE Paris Tech alumnus, class of 2006); the PhD program in Economics and Finance of Columbia Business School of Columbia University has imported and sponsored Professor Noemie Pinardon-Touati (ENSAE Paris Tech alumna, class of 2016); SC Johnson College of Business of Cornell University has imported and sponsored Professor Khaled Boughanmi (ENSAE Paris Tech alumnus, class of 2013); the PhD program in Finance of Yale School of Management has imported and sponsored Professor Paul Fontanier (ENSAE graduate, class of 2015); the PhD program in Business Economics of Harvard Business School of Harvard University has imported and sponsored Professor Stefanie Stantcheva (ENSAE Paris Tech alumna, class of 2009) and Professor Vincent Pons (ENSAE Paris Tech alumnus, class of 2006); and the PhD program in Finance of Sloan School of Business of MIT has recently imported and sponsored Professor Arnaud Costinot (ENSAE Paris Tech alumnus, class of 2000), Professor David Thesmar (ENSAE Paris Tech alumnus, class of 1996), and Professor Lionel Martellini (ENSAE Paris Tech alumnus, class of 1995), etc. It’s also worth noting that these imported ENSAE Paris Tech graduate Professors do all have high salary. For example, you can check here, Professor David Sraer’s salary at UC-Berkeley in 2022 was $409,642. Admission staff and OCR investigators don’t want African Americans like me to get these high paying jobs. They prefer giving these high paying US jobs to our non-underrepresented foreign citizen peers. Thus, by backing admission staff denying me admission and preferring importing my non-underrepresented foreign ENSAE Paris Tech graduate peers rather than admitting and training an African American ENSAE Paris Tech graduate like me, OCR investigators do actually work for foreign interests.

Let’s take another example, the case of Professors of Actuarial Science. USA is in shortage of academic actuaries (Professors of Actuarial Science with actuarial certifications of the American Society of Actuaries (SOA) and/or Casualty Actuarial Society (CAS)) that can address research and education needs of the U.S. actuarial profession, including both the theoretical and practical aspects. Each year, U.S. universities import and/or sponsor foreign Professors of Actuarial Sciences. The American actuarial professional organization SOA did even created James C. Hickman Scholarships (4 to 5 new scholarships per year; $20,000 each; renewable up to 4 times) to encourage American PhD students (those who can pass SOA/CAS actuarial certification exams) to get certified actuary and become academic actuary. The scholarship program was named after late Professor James C. Hickman, an academic actuary, former Dean of the University of Wisconsin–Madison School of Business. Preparing and passing actuarial certification exams are difficult and time consuming. As a consequence, the USA still don’t have enough American PhD students to take the James Hickman Scholarships. Each year, the SOA gives away 80% to 100% of the scholarships to foreign PhD students (free money of up to $80,000) to encourage the foreign PhD students to stay to work in the USA or Canada after the end of their PhD studies. I can pass the SOA/CAS actuarial certification exams and I do already have the preferred qualification for the academic actuary job (SOA/CAS actuarial certification exams). The only thing remaining that prevents me from starting the academic actuary career is a PhD diploma. Therefore, it’s in the interest of the USA to admit and train the qualified underrepresented African American candidate like me to become an academic actuary. Unfortunately, instead of working for that national interest of the USA, OCR investigators do knowingly, intentionally, willfully choose to work for foreign interests by backing admission staff barring me from accessing PhD study and by backing universities preferring admitting less qualified non-underrepresented foreign PhD candidates, and/or by indirectly backing universities preferring importing non-underrepresented foreign Professors of Actuarial Science rather than admitting and training qualified underrepresented African American ideal candidate like me.

It’s also worth noting that, thanks to OCR investigators' support of the exclusion of Blacks/African Americans like me, the actuarial professional organization Society Of Actuaries (SOA) in Schaumburg, IL does also directly or indirectly back universities preferring admitting and financing less qualified foreign PhD applicants rather than admitting and financing better qualified African American PhD applicants like me. In fact, SOA knows that ENSAE Paris Tech graduates are well suited for research activities in Actuarial Science. The SOA did even import and/or sponsor and/or hire an ENSAE Paris Tech alumnus, David Schraub (ENSAE alumnus, class of 1996) to be SOA’s staff actuary working in research and innovation in “Corporate Finance and Enterprise Risk Management (CFE)” (see here and/or here ). So, when SOA learned that a couple of Congressmen/Congresswomen were going to look at the SOA’s James Hickman scholarships web site, the SOA hided the web pages during almost one year. The reason is the web pages clearly showed that the universities and the SOA preferred training and financing foreign PhD students to take the Professor of Actuarial Science jobs in USA rather than training and financing qualified African Americans such as an ENSAE Paris Tech graduate like me. i.e. The SOA didn't want the Congressmen/Congresswomen to see the facts. When SOA republished the James Hickman scholarships web pages, it changed the scholarship package: instead of saying a stipend of $20,000 USD per academic year, SOA said “a stipend of an amount up to $20,000 USD per academic year (stipend amount may vary by country)”; also, instead of saying renewable 4 times ($80,000 stipend package), SOA said the scholarship is “renewable up to two times upon... the availability of adequate funding”. Furthermore, I don’t know if the SOA did also advise the universities with PhD programs in Actuarial Science to hide something, but I did see the following facts during that time: the Actuarial Science Department of Wisconsin Business School of University of Wisconsin – Madison rushed to change the name of the person in charge of its PhD program in Actuarial Science (it changed it from Professor Ping Shi to Professor Tyler Leverty ); the PhD program in Actuarial Science of University of Wisconsin - Madison did also “diversify” its monoracial students body by admitting one non-underrepresented non-minority applicant; the Actuarial Science program of University of Illinois Urban Champaign did also hurry to temporary hire a Black instructor (a Black student preparing a MS in Accounting at Gies College of Business of University of Illinois Urban Champaign) in order to “diversify” its monoracial faculty at that time; also having learned the existence of my current web site, the Actuarial Science program of University of Illinois Urban Champaign did also hurry to temporary import/hire a Black faculty (Professor Tolulope Fadina), etc.

Let’s take another example of preference for foreigners by universities and OCR investigators: the case of Professors of Finance. I recall that each year USA import and sponsor 50 to 100 (non-underrepresented) foreign Professors of Finance. I also recall that Actuarial Science is Mathematics, Statistics, Economics and Finance used in insurance and finance industry. I want to be an academic actuary specialized in Corporate Finance and Enterprise Risk Management(CFE) and/or Quantitative Finance and Investment(QFI). It’s called Professor of Finance with specialization in Actuarial Science and/or Professor of Actuarial Science with specialization in Corporate Finance and/or Investment. You can find here a sample of my Statement of Purpose (SoP) I submitted with my applications for admission. The PhD study in Finance with concentration in Corporate Finance and/or Asset Pricing constitutes a preparation for this academic actuary career with specialization in CFE and/or QFI. In fact, the SOA/CAS actuarial certification exams for the specialization in CFE and QFI - such as Foundations of Corporate Finance Exam, Enterprise Risk Management Exam, Quantitative Finance Exam, Portfolio Management Exam, and Investment Risk Management Exam - are all based on PhD courses in Finance. I also recall that I am an ideal candidate for the PhD program in Finance, and I can directly pass the PhD qualifying examination of the PhD program in Finance. i.e. I can finish the PhD study in Finance in 3 to 4 years instead of 5 to 6 years. The point is admission staff and OCR investigators have no lawful reason to bar me from accessing PhD study in Finance. This is particularly true for the top ranking universities because they do all receive federal financial assistance and that makes them to have a responsibility to address race/origin/age discriminations against me. I also recall that 25% to 50% of candidates admitted each year to the PhD programs in Finance are foreign citizens that are less qualified than an African American ideal candidate like me. The PhD in Finance career is very lucrative too. Let's take the example of non-underrepresented person Sebastien Plante: he got his PhD in Finance in 2018 from University of Pennsylvania, and his entry level salary as an Assistant Professor of Finance at University of Wisconsin-Madison was $300,000 per year. Thus, by indirectly backing universities preferring admitting less qualified non-underrepresented foreign PhD applicants and/or by indirectly backing universities preferring importing/sponsoring non-underrepresented foreign Professors of Finance to take these high paying Professor of Finance jobs rather than training qualified African Americans like me, OCR investigators do actually work for foreign interests and directly or indirectly participate in defrauding USA.

8 . Conclusion

The racism and discrimination against Blacks/African Americans are rampant in US universities' PhD admission. Hypocrisy, lies, and intellectual dishonesty have become the norm of the admission staff when it comes to admission of qualified Blacks/African Americans like me. PhD programs in Mathematics, Statistics, Economics, Finance and Actuarial Science in USA have become virtually inaccessible by qualified Blacks/African Americans like me. Unfortunately, this racism against and exclusion of Blacks/African Americans have always been backed by investigators of the Office for Civil Rights of the US Department of Education.