• “The NCAA enforcement staff failed, even after repeated requests, to interview many essential witnesses of great integrity who could have provided first-hand testimony, including, unbelievably, Paul Dee, who has since passed away, but who served as Miami Athletic Director during many of the years that violations were alleged to have occurred. How could a supposedly thorough and fair investigation not even include the Director of Athletics?

• “Finally, we believe the NCAA was responsible for damaging leaks of unsubstantiated allegations over the course of the investigation.

“Let me be clear again: for any rule violation — substantiated and proven with facts — that the University, its employees, or student-athletes committed, we have been and should be held accountable. We have worked hard to improve our compliance oversight, and we have already self-imposed harsh sanctions.

“We deeply regret any violations, but we have suffered enough.

“The University and counsel will work diligently to prepare our official response to the Notice of Allegations and submit it to the Committee on Infractions within the required 90-day time period.

“We trust that the Committee on Infractions will provide the fairness and integrity missing during the investigative process.”

One source familiar with the NCAA’s initial draft of UM’s Notice of Allegations — reviewed before the NCAA amended the allegations for the final version — said the charges “could have been worse but they’re still pretty bad.

“It’s more than a slap on the wrist. It will be upsetting. But there’s nothing shocking in there.”

A UM official said the NCAA “has given Shapiro far too much credence and run with a lot of what he said.”

According to an NCAA source, UM has asked the NCAA for permission to appear before the Committee on Infractions during a scheduled committee meeting on Saturday. The NCAA has expressed reluctance to allow UM on the calendar on such short notice.

UM wanted to meet with the committee this soon to deal with preliminary issues and try to expedite the process.

The NCAA’s investigation stemmed from former booster and now imprisoned Ponzi-schemer Nevin Shapiro’s accusations of rampant violations first documented in depth in a Yahoo! Sports report in August 2011.

Shapiro, serving a 20-year prison sentence, said that among the impermissible benefits he provided were cash, prostitutes, entertainment in his multimillion-dollar homes and yacht, paid trips to expensive restaurants and nightclubs, jewelry, bounties for on-field play and travel to athletes.

Shapiro gave the NCAA a list of 114 UM athletes, most of them former football players, and the NCAA tried to interview everyone possible. At one point the NCAA sent ultimatums in letters to the athletes and/or their attorneys, urging them to talk about “their knowledge of or involvement in possible NCAA violations concerning [UM]” or “the staff will consider the non-response” as an “admission of involvement in NCAA violations.”

Now, more waiting.

The next phase of the process normally involves the university, as well as the individuals alleged to have committed penalties, submitting written responses to the allegations. Individuals respond only to their specific alleged wrongdoings.