In the mid grad area you are thinking of it is less likely to find a fake in a slab. It is a lot of work for $150 for most scammers. They think bigger if they are going to take the time. It is true though that it has been known to happen. I have never seen a BGS or BVG (beckett grading) slabs tampered with, but a lot of people don't like the size (which is the same reason they are hard to tamper with).
PSA is the most commonly used slab to tamper because it is the largest company and commands the most premium for this years of baseball cards, so that extra premium attracts scammers. This doesn't mean that most of them are faked though.
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