2 Article 79.1 Higher Education’s Gainful Employment and 90/10 Rules: Unintended “Scarlet Letters” for Minority, Low-Income, and Other At-Risk Students Anthony J. Guida Jr Senior Vice President, External Affairs, Education Management Corporation David Figuli Partner, Figuli Law Group We would like to thank Chad Garrett for his excellent assistance with gathering the data needed for this Article. Education Empirical Analysis Institutional Design