Not everything unusual is wrong.Some of it is provable.

Compensation was paid on subscriber relationships that had terminated, in a population that no reactivation, transfer or reporting delay accounts for.

Clawback provisions in the dealer agreements were enforceable but were not triggered, because the trigger depended on an event that never crossed system boundaries.

A concentrated subset of dealers accounted for a disproportionate share of the affected population, sustained across the full period rather than clustered around any single month.

A measurable population received payments during periods when no eligibility determination was in force.

The majority of that population reflects administrative lapse rather than substantive ineligibility, which changes the remedy but not the exposure.

The two prior reviews are both arithmetically correct and are not comparable, because they measure different populations.

Provisional credits remained outstanding after the underlying dispute was decided against the cardholder.

A population of disputes was credited through two intake channels for the same underlying transaction.

Network representment rights lapsed unused on a measurable subset of eligible disputes.

Accessorial charges were invoiced and paid with no corresponding operational event in the shipment record.

Invoiced rates exceeded the rate in force under the governing schedule at the date of service.

Amendment effective dates were applied inconsistently between the vendor and the client.