Report 2018-132 Recommendation 6 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 #6 To: Justice, Department of

To ensure that its licensing process is transparent and consistent, the bureau should implement formal procedures for prioritizing its completion of legal reviews of ownership applications. The procedures should specify any circumstances that justify reviewing applications out of the order in which the bureau received them.

60-Day Agency Response

BGC has established a formal policy for prioritizing legal review of transactions, which directs that legal review of transactions must be conducted on a first-in and first-out basis with certain delineated exceptions. BGC's in-house DAG has been completing transactions pursuant to this policy.

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

The bureau's new policy is consistent with its description and delineates some exceptions to the first-in, first-out basis, such as issues with the health of a card room owner. The policy also identifies "other exigencies as applicable as determined" as possible deviations from the policy. Given the breadth of potential exceptions to the first-in-first-out approach, the bureau should clearly document its specific rationale for individual applications so it can justify those decisions to the applicants.

All Recommendations in 2018-132

Agency responses received are posted verbatim.