On February 23, 2011, the Regional Administrator signed a Final Determination in connection with violations self-disclosed by Carroll University. Following a campus-wide audit required by an Audit Policy Agreement between the U.S. Environmental Protection Agency and the Wisconsin Association of Independent Colleges and Universities, Carroll University submitted an Initial Disclosure Report on May 5, 2010 disclosing possible non-compliance with the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, the Emergency Planning Community Right-to-Know Act, and the Toxic Substances Control Act. Based upon a December 2010 Final Compliance Report, EPA concluded that Carroll University had met all of the criteria set forth in the Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, otherwise known as the Audit Policy. EPA mitigated the civil penalty by 100% and determined that any economic benefit Carroll University would have obtained from the self-disclosed violations is insignificant.