Wednesday, December 31, 2025

PART IV What Comes Next: Scenarios, Predictions, and The Divestment Scorecard

PART IV: WHAT COMES NEXT

PART IV

What Comes Next: Scenarios, Predictions, and The Divestment Scorecard

The Future Is Being Written Now

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You've seen the pattern. You've seen the evidence. Now the question is: what actually happens next?

This isn't speculation for entertainment. This is scenario modeling based on documented patterns, financial realities, and structural forces already in motion.

What follows is:

  • Three scenarios for how this unfolds (2026-2030)
  • The Divestment Scorecard ranking the top 25 schools by LLC probability
  • Timeline predictions with specific dates
  • Signals to watch that tell you which scenario is happening

This is your roadmap for understanding the transformation as it unfolds.

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Scenario 1: The Gradual Professionalization (Probability: 45%)

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THE OPTIMISTIC CASE: "Soft Landing"

Core assumption: The transformation happens but is managed carefully enough to avoid catastrophic disruption. Most major programs survive the transition.

How It Unfolds (2026-2030)

2026:
  • Q1: 3-5 additional schools announce LLC formations (likely: Florida State, Clemson, Michigan, Texas A&M)
  • Q2: First PE deal after Utah announced (candidate: Florida State with Sixth Street Partners)
  • Q3: IRS issues guidance on athletic LLC tax treatment - cautious but doesn't immediately revoke 501c3 status
  • Q4: Big Ten announces "structural flexibility" allowing member schools to create LLCs
2027:
  • Q1-Q2: 10-15 schools total have formed LLCs; pattern clear but not universal
  • Q2: First Title IX lawsuit targeting revenue-sharing allocation filed
  • Q3: SEC announces similar "structural modernization" framework
  • Q4: NCAA creates "Division I-Premium" classification for LLC-structured programs
2028:
  • Q1: First athlete employment case reaches settlement - athletes in LLC structures deemed employees
  • Q2: 20-25 schools operating as LLCs, mostly Power 2 (Big Ten/SEC)
  • Q3: Conference revenue distribution changes to reflect LLC vs. traditional structures
  • Q4: First collective bargaining agreement discussions begin
2029:
  • Q1-Q2: "Super Conference" formalized - Big Ten/SEC merge business operations while maintaining separate brands
  • Q3: Traditional athletic departments announce major Olympic sports cuts (5-10 sports eliminated at multiple schools)
  • Q4: First schools exit athletic competition entirely (mid-tier programs can't afford new model)
2030:
  • By end of year: 35-40 schools operating as LLCs with PE backing
  • Clear two-tier system: LLC-backed "Professional College Sports" vs. traditional "Amateur Athletics"
  • NCAA essentially governs only traditional tier; LLC tier self-governs

Characteristics of This Scenario

  • Regulatory response is measured: IRS/DOL issue guidelines but don't immediately shut down LLC structures
  • Litigation is slow: Title IX and employment cases take years to resolve; schools adapt as they go
  • PE capital flows steadily: More firms enter market; deal structures become standardized
  • Conference consolidation accelerates but doesn't collapse: Power 2 dominate but ACC/Big 12 survive in diminished form
  • Olympic sports shrink dramatically but don't disappear: 30-40% of non-revenue programs eliminated
  • Traditional model persists at smaller scale: Group of 5, FCS continue with traditional structure
"In this scenario, the transformation succeeds but takes a decade. The Big Three locomotive companies had 30+ years to adapt and still failed. College athletics gets 5-7 years and some survive. That counts as success."
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Scenario 2: The Regulatory Collapse (Probability: 30%)

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THE PESSIMISTIC CASE: "Hard Landing"

Core assumption: Regulatory agencies and courts intervene aggressively, creating crisis that forces rapid, chaotic restructuring.

How It Unfolds (2026-2028)

2026:
  • Q2: IRS announces investigation of Kentucky/Utah LLC structures for tax-exempt status violations
  • Q3: Title IX lawsuit wins preliminary injunction - court orders 50/50 split of revenue sharing between male/female athletes
  • Q4: Schools face impossible choice: comply with Title IX (can't afford) or lose federal funding (can't survive)
2027:
  • Q1: Department of Labor rules all athletes receiving revenue sharing are employees under FLSA
  • Q2: First school declares athletic department bankruptcy; spins off football/basketball to separate for-profit entity
  • Q3: Congressional hearings on "The Professionalization of College Sports"
  • Q4: Proposed legislation to either (a) explicitly allow professionalization with regulation, or (b) ban it entirely
2028:
  • Q1-Q2: Legislation stalls; regulatory chaos continues
  • Q3: Mass Olympic sports eliminations (50-100 programs killed nationally)
  • Q4: Big Ten/SEC announce complete separation from NCAA - form independent "American Football League"

Characteristics of This Scenario

  • Regulatory crackdown is swift and aggressive: IRS, DOL, courts all rule against LLC structures simultaneously
  • Title IX becomes existential crisis: 50/50 revenue split mandated; schools can't comply financially
  • PE firms pull back: Legal uncertainty makes investments too risky; capital dries up
  • Bankruptcy and exits accelerate: 10-15 schools exit Division I athletics entirely
  • Football/basketball separate completely: Become standalone professional leagues with university licensing agreements
  • NCAA collapses: Loses all major schools; becomes insignificant governing body
Why This Could Happen:

The locomotive industry collapsed in ~20 years despite decades of warning. College athletics has 5-7 years and much more aggressive regulatory oversight. If IRS/DOL/courts all rule against the new structures simultaneously, the system can't adapt fast enough. Collapse is possible.

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Scenario 3: The Super League Acceleration (Probability: 25%)

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THE WILD CARD: "Clean Break"

Core assumption: Top 30-40 programs decide fighting regulation is futile; they exit NCAA entirely and form professional league immediately.

How It Unfolds (2026-2027)

2026:
  • Q2: Confidential meetings among Big Ten/SEC athletic directors and PE firms
  • Q3: Leaked: "Project Apex" - proposal for 32-team professional football league independent of NCAA
  • Q4: Public announcement: "American College Football League" launching 2027 season
2027:
  • January: 32 founding members announced (all Big Ten/SEC plus select others)
  • February-May: Frantic legal/operational work to establish league structures
  • August: First season of "ACFL" kicks off - explicitly professional, players are employees, collective bargaining in place
  • September-December: Massive litigation from NCAA, left-out schools, state attorneys general

Characteristics of This Scenario

  • Sudden, coordinated break: Top schools exit simultaneously to avoid being picked off individually
  • Explicit professionalization: No pretense of amateurism; openly professional from day one
  • Massive PE backing: $5-10 billion in PE capital funds launch; investors get equity in league
  • University connection maintained minimally: Teams license university brands but operate independently
  • Everyone else left behind: ACC, Big 12, Group of 5 scramble to survive in new landscape
  • NCAA becomes minor leagues: Governs remaining "amateur" athletics; major decline in relevance
"This is the MLS model applied to college football. Single-entity league owned by PE and founding members. University connection is branding only. It's the cleanest solution—and the most radical."
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The Divestment Scorecard: Top 25 Programs

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Based on revenue, financial pressure, state laws, institutional culture, and conference affiliation, here are the 25 schools most likely to create LLC structures and pursue PE partnerships by 2027:

Rank School Revenue (FY24) Valuation LLC Probability Key Factors
1 Florida State $180M $1.01B 95% ACC exit motivation, financial crisis from low media payout, aggressive leadership, Florida law permits
2 Clemson $170M $970M 90% Joined FSU in ACC lawsuit, similar financial pressure, South Carolina law favorable
3 Texas A&M $279M $1.32B 85% Massive revenue with aggressive growth, donor base comfortable with commercialization, Texas law permits
4 Michigan $211M $1.16B 80% Huge revenue, just proved NIL willingness (Bryce Underwood), Michigan law permits public university LLCs
5 USC $242M $1.06B 80% Private school (more flexibility), California location, Big Ten move shows commercial mindset
6 Penn State $190M $1.04B 75% Massive revenue, Pennsylvania law allows, conservative culture may slow adoption
7 LSU $200M $1.02B 75% Strong revenue, Louisiana law permits, SEC competitive pressure
8 Texas $332M $1.48B 70% Highest revenue/valuation but less financial pressure; may not need PE immediately
9 Ohio State $255M $1.35B 70% Massive resources, Ohio law permits, but less urgency due to strong current position
10 Tennessee $210M $1.05B 70% Strong SEC position, Tennessee law allows, competitive pressure mounting
11 Auburn $175M $940M 65% SEC arms race, Alabama law permits, needs edge over Alabama
12 Georgia $242M $1.16B 65% Elite revenue but conservative leadership may hesitate; Georgia law uncertain
13 Alabama $235M $1.09B 65% Post-Saban transition creates urgency, but strong traditional donor base may resist
14 Oklahoma $200M $1.00B 60% SEC move expensive, Oklahoma law permits, needs resources to compete
15 Nebraska $205M $1.06B 60% Surprising revenue strength, passionate fanbase, Big Ten competitive pressure
16 Florida $200M $980M 55% Strong revenue but conservative administration, Florida law permits
17 Notre Dame $220M $1.04B 50% Private (flexibility) but independent status and traditional culture create resistance
18 Oregon $205M $945M 50% Nike backing provides alternative to PE, Oregon law unclear on public university LLCs
19 Wisconsin $180M $900M 45% Strong academics-first culture, Wisconsin law restrictive for public universities
20 Arkansas $165M $870M 45% SEC pressure but smaller revenue base, Arkansas law permits
21 South Carolina $160M $840M 40% SEC arms race, but conservative state politics may complicate
22 Iowa $175M $880M 40% Strong wrestling/Olympic programs create Title IX complexity, Iowa law unclear
23 Washington $165M $860M 35% Big Ten move expensive, Washington law restrictive for public entities
24 Ole Miss $150M $810M 35% SEC pressure, Mississippi law permits, but smaller revenue base limits PE interest
25 North Carolina $155M $830M 30% Academic prestige creates resistance, North Carolina law uncertain, ACC instability

Tier Key:

  • High Probability (80%+): Likely to announce LLC formation by end of 2026
  • Medium Probability (50-75%): Likely by 2027-2028
  • Lower Probability (30-45%): May eventually follow but significant barriers
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What To Watch: The Signals

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Here are the specific developments that will tell you which scenario is unfolding:

Signals for Scenario 1 (Gradual Professionalization)

Green Lights:
  • IRS issues cautious guidance that doesn't immediately revoke 501c3 status but sets conditions
  • 3-5 schools announce LLCs within 6 months of Utah (shows pattern is replicable)
  • More PE firms enter market (Sixth Street, RedBird, others announce deals)
  • Big Ten/SEC officially endorse LLC structures for member schools
  • Title IX lawsuits settle rather than going to trial (creates manageable precedent)
  • Employment cases resolve incrementally over years, not months

Signals for Scenario 2 (Regulatory Collapse)

Red Flags:
  • IRS announces investigation of Kentucky/Utah specifically targeting tax-exempt status
  • Title IX lawsuit wins major preliminary ruling requiring 50/50 revenue split
  • DOL issues broad employment classification ruling that applies to all revenue-sharing athletes
  • Congressional hearings with hostile tone toward professionalization
  • No additional schools announce LLCs within 6 months (shows Kentucky/Utah are isolated, not leading edge)
  • PE firms pull back from announced deals due to regulatory uncertainty
  • First school declares athletic bankruptcy or exits Division I

Signals for Scenario 3 (Super League Acceleration)

Purple Smoke:
  • Leaked meetings between Big Ten/SEC ADs and major PE firms about "structural alternatives"
  • Coordinated statements from multiple schools about "exploring all options" for sustainability
  • Major PE firm announces $5B+ fund specifically for college athletics transformation
  • Big Ten/SEC announce joint "working group" on governance reform
  • Media reports of "Project [Codename]" - secret planning for breakaway league
  • Sudden conference realignment freeze - schools stop moving, suggesting coordinated plan
  • NFL/NBA owners publicly discuss investing in college football restructuring

The Quarterly Update Framework

This document will be updated quarterly with:

  • New LLC formations: Which schools announced, deal terms if disclosed
  • PE deals: Who invested, how much, structure details
  • Regulatory developments: IRS guidance, court rulings, legislative action
  • Scorecard revisions: Updated probabilities based on new evidence
  • Scenario probability adjustments: Which scenario is looking more/less likely

Next scheduled update: March 31, 2026

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Timeline Predictions: Specific Dates

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Based on the patterns we've documented, here are specific, falsifiable predictions:

2026 Predictions:

By March 31, 2026:

  • At least 2 additional schools announce LLC formation (prediction: Florida State + one other)
  • First PE deal after Utah is either announced or reported as "in negotiations"
  • IRS begins review of athletic LLC structures (may not be public immediately)

By June 30, 2026:

  • Total of 5-7 schools with announced LLC structures
  • Big Ten or SEC makes official statement on member school flexibility
  • First Title IX lawsuit specifically targeting House settlement allocation filed

By September 30, 2026:

  • At least one additional PE firm (beyond Otro) announces college athletics investment
  • Revenue-sharing cap for 2026-27 announced (~$21.3M with 4% increase)
  • First school announces Olympic sports cuts explicitly linked to revenue-sharing costs

By December 31, 2026:

  • 10+ schools total with LLC structures or announced plans
  • First employment case specifically involving LLC-employed athlete reaches court
  • Congressional hearing scheduled for early 2027
2027 Major Events (Predicted):
  • Q1 2027: IRS issues preliminary guidance on athletic LLC tax treatment
  • Q2 2027: First Title IX case reaches summary judgment or settlement
  • Q3 2027: 15-20 schools operating as LLCs; pattern undeniable
  • Q4 2027: NCAA announces "Division I restructuring" to accommodate LLC vs. traditional models
2028-2030 Critical Junctures:
  • 2028: First employment collective bargaining agreement OR first regulatory shutdown of LLC model (binary outcome)
  • 2029: Conference structure finalizes into "Super Conference" + remnants OR fragmented chaos
  • 2030: Either 35-40 schools operating professionally as LLCs (Scenario 1), OR complete collapse into breakaway league (Scenario 3), OR regulatory lockdown with scattered casualties (Scenario 2)

How To Track These Predictions

I will maintain accuracy by:

  • Documenting each prediction with date made and specific claim
  • Updating quarterly with hits, misses, and refinements
  • Adjusting probabilities based on actual outcomes
  • Acknowledging wrong predictions explicitly and analyzing why

This isn't fortune-telling. It's pattern completion based on documented historical parallels and current evidence. Some predictions will be wrong. But the framework should hold.

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For Athletic Directors, University Presidents, and Boards

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If you're in a position to influence your institution's response to this transformation, here's what you need to know:

Questions Your Board Should Be Asking Right Now

Financial Sustainability:
  1. What is our plan to fund $20.5M+ in annual revenue sharing starting 2025-26?
  2. Can we sustain this from operating revenue, or do we need new capital sources?
  3. What happens when the cap increases 4% annually? Can we afford $32M by 2035?
  4. Have we modeled a 10-year budget that includes revenue sharing + NIL + facilities?
Legal Exposure:
  1. What is our liability exposure if athletes are deemed employees?
  2. How are we protecting the university's endowment and academic assets from athletic department litigation?
  3. Have we evaluated LLC structure for liability firewall purposes?
  4. What is our Title IX compliance strategy given 90/10 revenue-sharing splits?
Competitive Position:
  1. If our conference peers create LLCs with PE backing, can we compete without doing the same?
  2. What happens to our recruiting if we can't match competitors' financial resources?
  3. Is our current governance structure fast/flexible enough for this environment?
Strategic Options:
  1. Have we explored LLC formation as Kentucky/Utah have done?
  2. Have we had preliminary conversations with PE firms about potential partnerships?
  3. What would transition to LLC structure require (legally, politically, operationally)?
  4. What's our Plan B if revenue-sharing becomes unsustainable under current model?

The Adaptation Impossibility Reality

Remember the locomotive pattern: most incumbents can't adapt even when they see the threat.

If your institution:

  • Has strong "amateur athletics" identity
  • Has conservative board/administration
  • Operates in state with restrictive laws
  • Has faculty resistance to commercialization
  • Lacks relationships with PE firms
  • Has athletic department run by former coaches (not business operators)

...then you probably can't successfully execute the Kentucky/Utah transformation, no matter how necessary it is.

That doesn't mean you're doomed. But it means you need a different strategy:

Alternative Strategies for Schools That Can't Go LLC:

Option 1: Strategic Niche

  • Accept you won't compete for national championships
  • Focus on regional success and sustainable model
  • Downsize to Group of 5 or FCS if necessary
  • Emphasize Olympic sports and academic integration

Option 2: Conference Collective

  • Pool resources at conference level (Big 12 exploring this)
  • Conference-wide PE partnership rather than school-by-school
  • Shared costs, shared benefits, reduced individual risk

Option 3: Early Exit

  • Recognize the new model is unsustainable for your institution
  • Exit Division I football before financial crisis forces it
  • Preserve other sports programs and institutional finances
  • Market as "return to educational mission" rather than failure

The locomotive pattern shows that denial is the most common response, followed by half-measures that don't address the fundamental problem. Don't be Baldwin building the Centipede.

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For Fans, Media, and Observers

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If you're watching this transformation from outside, here's how to understand what you're seeing:

What The "Chaos" Actually Is

Every confusing development isn't random. It's part of the pattern:

What You See What It Actually Is
"Conference realignment makes no geographic sense" Revenue optimization. Geography is irrelevant when it's a media product, not regional sports competition.
"NIL is out of control" Capital flowing to talent. This is how professional sports work. It looks chaotic because rules pretend it's not professional.
"Schools are cutting Olympic sports" Resource allocation to revenue-generating activities. Non-revenue sports are casualties of professionalization.
"The NCAA is powerless" Trade association losing authority as industry transforms around it. Exactly what happened to locomotive industry associations.
"Players want to be employees" Recognition that they already are. Legal fiction of amateurism collapsing under financial reality.
"Private equity in college sports" Financialization. College athletics are becoming investment vehicles generating returns for capital.

The Questions To Ask

When reading coverage of college athletics developments, ask:

  • "Who benefits financially from this?" Follow the money, not the rhetoric.
  • "Is this about competition or capital?" Most decisions are now financial, not competitive.
  • "Does this bring college athletics closer to professional sports?" The direction is one-way.
  • "What's the business model rationale?" There's always one, even if not stated explicitly.

What You'll Lose (And Won't)

What's dying:

  • The fiction of "student-athletes" playing for love of sport
  • Geographic rivalries defining conference membership
  • Amateur athletics as core university mission
  • NCAA as meaningful governing body
  • Broad-based Olympic sports programs
  • Free access to athletes (NIL rules restrict media contact)

What's not dying:

  • The games themselves (football will still be played)
  • Fan passion (probably intensifies with higher stakes)
  • University branding (schools still license names/logos)
  • Regional loyalties (you'll still root for "your" team)
  • The quality of play (likely improves with professionalization)

The product isn't disappearing. It's transforming. Whether that's better or worse depends on what you valued about college athletics in the first place.

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The Pattern Completes

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Let's bring it all back to where we started: the locomotive industry.

In 1963, Alco introduced the Century 636—3,600 horsepower, technically superior to anything EMD offered. Six years later, Alco was gone.

In 2025, traditional athletic departments are still focused on facilities, coaching, recruiting—the competition metrics. Kentucky and Utah restructured as LLCs with PE backing—the business model innovation.

The parallel is exact. The pattern is repeating.

"The Big Three had 30+ years to adapt and failed. College athletics has 5-7 years. The schools that understand they're playing the wrong game have a chance. The schools that think better facilities and coaching will save them are building the Centipede—technically impressive, commercially doomed."

What Comes After 2030?

By 2030, assuming Scenario 1 or 3 (not collapse), college football will be:

  • Explicitly professional (employment, collective bargaining)
  • PE-backed and managed by sports business operators
  • University-affiliated but operationally independent
  • Concentrated in 30-40 elite programs
  • Generating massive returns for investors
  • Completely separate from educational mission except branding

This is the MLS/European football club model applied to American college athletics. University connection becomes similar to how Manchester United represents Manchester—geographic/historical identity, not actual university integration.

The traditionalists will mourn. The investors will celebrate. The games will continue.

And somewhere, the ghost of EMD's success will look at Kentucky and Utah and say: "Yeah, that's how you do it. That's how you win."

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The Transformation Is Happening

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You've seen the pattern. You've seen the evidence. You've seen the predictions.

Kentucky and Utah are EMD. Traditional athletic departments are the Big Three.

The game has changed. Most schools don't realize it yet.

Excellence at the old game won't save you from losing the new one.

This analysis will be updated quarterly as the transformation unfolds.

Next update: March 31, 2026

Watch. Document. Remember you saw it here first.

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END OF SERIES
Total Analysis: ~33,000 words
Created through human-AI collaboration
December 2025

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