That complaint also sparked an investigation by the department’s Office for Civil Rights, which identified “concerns and a violation” last year with UNC’s Title IX compliance. But with the Clery Act investigation’s larger scale and “significant” determinations, Clery Act expert S. Daniel Carter said, UNC now faces potentially substantial federal fines.

The final report was based on nine individual findings of UNC being out of compliance over the review period that were identified by the department in its initial February 2017 review report. Those findings were categorized as:

• Lack of Administrative Capability
• Failure to Properly Define the Campus/Clery Geography
• Failure to Issue Timely Warnings
• Failure to Properly Compile and Disclose Crime Statistics
• Discrepancies between the Crime Statistics Included in the ASR and the Data Submitted to the Campus Safety and Security Data Analysis Cutting Tool
• Failure to Collect Campus Crime Information from All Required Sources
• Failure to Follow Institutional Policy in a Case of an Alleged Sex Offense
• Failure to Disclose Accurate and Complete Disciplinary Referral Statistics - Failure to Retain Records Needed to Substantiate Clery Act Compliance
• Failure to Include Required Information in the Annual Fire Safety Reports

The report sustained all except for one of these findings, the exception being the finding of “Failure to Disclose Accurate and Complete Disciplinary Referral Statistics - Failure to Retain Records Needed to Substantiate Clety Act Compliance.”

The Clery Act division’s review began with a campus visit in April 2013 with the aim of reviewing UNC's incident reports, arrest records, and student and employee disciplinary documents. The review was later expanded to review “the accuracy and completeness of the University's crime statistics through the end of calendar year 2015,” according to the report.

The review process then comprised years up to May this year of back-and-forth between the compliance division and UNC. The report noted that “despite the department's best efforts, it proved impossible to full (sic) reconcile (UNC’s) narrative response with most parts” of its file reviews.

The report also found that UNC’s issuance of Honor Court charges against former student Landen Gambill —  after she’d taken part in the complaint and spoken publicly about the University’s handling of her and others’ sexual violence reports  — constituted a violation of the Clery Act’s anti-retaliation provision.

“To read a letter by an impartial investigator that is this scathing, I think (it) sends a very clear message, and I really hope that readers take it as a call to action to continue to hold the University accountable,” said Andrea Pino, an alumna who took part in filing the initial complaint.

This a developing story. Check dailytarheel.com for updates.