STOs, regulation and the mortgage industry

As I read this, it makes me think there's a big opening for fraud. I'm not suggesting that's the case w/Yarbrough's STO. But we see what a lack of oversight has yielded for our mortgage industry, kids. So what I see here, is without oversite and/or regulation of STOs, an uninformed contributor could potentially contribute their tax credits to a sham organization that never delivers funds to a school and/or a child's tuition. In one solid year, with some good advertising, a fly by night STO could collect contributions, pocket money, and be gone before those dollars would ever be called for a child's tuition payment. And with a reciept from the STO, the state would still be required to honor that dollar-for-dollar reduction of tax liablitlies. After all, how could the state declare the STO was a fraud? There isn't a mechanism or industry standard that I've found that would prevent it.