Report 2018-132 Recommendation 14 Responses

Report 2018-132: Bureau of Gambling Control and California Gambling Control Commission: Their Licensing Processes Are Inefficient and Foster Unequal Treatment of Applicants (Release Date: May 2019)

Recommendation #14 To: Justice, Department of

To ensure that its level of review is commensurate to license type, the bureau should review and revise each of its background investigation procedures as needed by November 2019.

6-Month Agency Response

April 24, 2019:

- BGC reviewed its policies for each license type and created a new set of procedures that are utilized for work permits, TPPPPS players and supervisors, and key employees. While the tasks are consistent, the level of review is commensurate to license type. Accordingly, additional tasks are required for TPPPPS supervisors and cardroom key employees.

October 24, 2019:

- BGC established a single set of procedures for cardroom and TPPPPS owner license reviews.

- BGC established a policy outlining the steps required for management review of background investigations reports. At a minimum, first-line managers or their lead analysts must:

o Review applicable checklists to ensure compliance with all background investigation procedures

o Review case notes to ensure pertinent information is included in the investigation report.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

The bureau provided revised background investigation procedures that apply across license types to card room and third party staff, as well as procedures that apply across owner types. If bureau staff follow these procedures and managers enforce them consistently, these consolidated procedures will address inconsistencies we identified during our audit that subjected applicants with similar responsibilities to different levels of scrutiny during the application process.


60-Day Agency Response

CSA's recommendation was to review and revise each of its background investigation policies by November 2019. As of April 24, 2019, BGC reviewed its policies for each license type and created a new set of procedures that is utilized for work permits, Third Party Providers of Proposition Player Services (TPPPPS) players and supervisors, and key employees. While the tasks are consistent, the level of review is commensurate to license type. Accordingly, additional tasks are required for TPPPPS supervisors and cardroom key employees. BGC is currently developing a single set of procedures for cardroom and TPPPPS owner license reviews with an anticipated completion date of September 30, 2019. Additionally, BGC will establish a procedure for conducting periodic reviews to determine staff's compliance with the procedures.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

The bureau provided the revised procedures it references in its response. Once it has revised the remaining procedures, we will review them for consistency as well as to ensure that any differences are reasonable and commensurate with licence holders' level of responsibility.


All Recommendations in 2018-132

Agency responses received are posted verbatim.