Lies with upper management who, instead of building an actual sustainable business model, decided to just take the money and run. The big, immediate issue that is causing thousands of employees to now work for a failing business is that CCi didn't produce required documents when they were requested by the only legitimate entity that pays CCi anything, the Department of Education. With all of the internal audits that were constantly being done, there is no excuse for Massimino not arranging for those documents to be produced, other than that they were intentionally being withheld.
Now that the ship is sinking, the upper management is all scrambling to get out. Try calling an Everest or WyoTech campus today and get in touch with somebody in management. See how far you get. And now, it's looking increasingly likely that the company won't even be able to make payroll, because no one in upper management had any concern about any issue other than how to keep the milk flowing from the government teat.
A lot of people at the campus level were expressing concern about this business model as long as 5 years ago. Constantly increasing costs to remain compliant with 90/10 and starting an entire loan subsidiary because no one will finance your students and they can't afford to make payments was a holding action at best, and no one came up with a better idea. I don't feel bad that the shareholders and management are getting hosed, but I feel terrible for the employees who are not only out of a job, but, as of today, have officially worked two entire weeks that they likely won't get paid for. I guess that's what happens when you stick your finger in the eye of the only source of money that you have.