Cross-Entropy Risk Estimation for Language Models: Inconsistency Must Be Dense, and the Holdout Method Is No Exception

Language models are compared by their held-out per-token cross-entropy risk---the quantity scaling laws are fitted to. We show that it cannot be consistently estimated. Consistency, or convergence to the estimand, is defined relative to a \emph{possible state of the world}: a pair consisting of a data-generating distribution and a model we turn out to train. Quantifying over models as well as data-generating mechanisms is essential, because what decides whether a model's risk is estimable is a tail property of the distribution its weights induce, which no sample reveals. The per-token cross-entropy risk is hard to estimate because of a topological fact: among the possible states, finite risk and infinite risk each lie arbitrarily close to every instance of the other. Consequently no estimator---not merely the holdout average---is consistent at every state at which the risk is defined. Worse, inconsistent estimation persists under both bounding the expected sequence length and restricting to full-support models; and in that restricted setting the states at which inconsistency occurs are even dense. Two interesting ways out are identified, and neither is free. Way out 1: using a bounded context window, we can floor a model's next-token probabilities, making its risk finite exactly when the data-generating distribution has finite expected sequence length---a new, statistical rationale for a choice that was made on computational grounds, though the assumption it substitutes is itself beyond the reach of any test. Way out 2: reporting the risk only when it falls below a threshold fixed in advance restores consistency, at no cost to what model selection actually requires---but we need to recognize that the goal of estimation is revised.

Do Tabular Foundation Models Agree with Themselves?

Tabular Foundation Models (TFMs) are currently the best approach to tabular prediction problems. They are constructed as transformers that approximate the Bayesian posterior predictive distribution based on a pre-training prior. These univariate predictors can be converted into multivariate ones autoregressively by sampling one target and adding it to the features. However, the faithfulness of the resulting joint has not been investigated. Furthermore, TFMs cannot be evaluated against the posterior itself, at least not on real-world datasets, because the ground-truth distribution is unknown. We therefore propose asking a different question: could a model's predictions result from any joint distribution? To answer this question, we pose two requirements that any such model must satisfy. The first is marginalization consistency, which demands that marginalized conditionals are equal to directly predicted marginals. The second is factorization consistency, which demands that different factorization orders result in equal joint distributions. Every TFM that we evaluate violates both of these requirements for both classification and regression across all datasets.

Sublinearly Structured Deep Neural Networks Achieve Feature Learning Consistency for Compositional Functions

Over the past decade, deep neural networks (DNNs) have achieved remarkable success on complex machine-learning tasks, yet the theoretical foundations of their performance remain incomplete. From a statistical viewpoint, a natural question is: can DNNs attain feature-learning and prediction consistency comparable to that of classical models? While a full characterization is open, we provide positive results for a broad subclass. We establish feature-learning consistency guarantees for sublinearly structured DNNs-architectures whose input/output dimensions and number of hidden neurons grow sublinearly with the sample size-when learning hierarchically compositional target functions. Importantly, this consistency still holds even in the conventional "over-parameterized" regime where the total number of parameters exceeds the number of training samples. Empirically, sublinearly structured DNNs match or surpass wide DNNs in prediction. A structural audit further indicates that widely used convolutional neural networks (CNNs), including AlexNet, VGGNet, ResNet, GoogLeNet, are sublinearly structured on their image classification benchmarks. We further prove that the sublinearly structured DNNs achieve universal approximation for hierarchically compositional functions in the large-sample limit. Moreover, images exhibit an inherent hierarchical, compositional structure. Taken together, these results explain, through a statistical lens, why many large-scale deep learning models succeed after adequate training on massive image datasets.

A Bregman Perspective on Classification and Regression Trees

Classification and Regression Trees (CART) constitute one of the most influential paradigms in statistical learning. Although a variety of impurity measures have been proposed for different statistical models, these criteria are typically introduced on a case-by-case basis and analyzed separately. In this paper, we study CART through the lens of Bregman divergences. This perspective places the classical least-squares criterion, Poisson deviance, Kullback-Leibler-type losses, and other impurity measures associated with exponential-family models within a common framework. As a result, key ingredients of the CART methodology -- including node representatives, impurity measures, and split selection rules -- can be expressed and analyzed through general properties of convex functions rather than through separate model-specific constructions. Beyond the algorithmic formulation, we investigate theoretical properties of Bregman-based CART procedures. In particular, we analyze how geometric properties of the generating convex function influence impurity reductions and stability of recursive partitions. We also establish consistency results within the proposed framework, providing a unified theoretical treatment for a broad family of CART type procedures. Our results provide a geometric interpretation of impurity-based tree construction and show that many classical CART impurity criteria admit a common interpretation within a Bregman framework.