This study used 1994 data from the California Community College System cohort of first-time freshmen to identify that part of University of California (UC) or California State University (CSU) transfer performance that is determined by factors outside the control of college administrators. The idea was to "level the playing field" when comparing transfer rates of various colleges by adjusting for factors beyond the control of colleges. Relevant uncontrollable factors included distance to the nearest CSU/UC campus, the number of students under the age of 25, the number of students receiving the Board of Governors Waiver, and the number of students with an uninformed transfer goal. The study identified colleges in the bottom quartile of the distribution of raw transfer rates as"low-transfer" colleges. A multiple regression model was developed using those predictors that had a meaningful contribution to prediction of raw transfer rates. Colleges were sorted in order of residuals (the amount by which raw transfer rate differed from predicted transfer rate). If a college remained in the bottom quartile of adjusted transfer rates, this college was considered a bonafide low-transfer college. The analysis placed 14 (rather than 26) colleges in the low-transfer category. (PGS)