Dear Editor:
At the September 10, 2025 Finance Advisory Committee (FAC) meeting, Culver City’s Internal Audit Manager (IAM), a Senior Management Analyst, presented a status report on the City’s Fraud, Waste, and Abuse (FWA) system. The staff report said 49 hotline tips had been received since the program’s launch and that “all cases have been reviewed and closed.” When a member asked about the “kinds of cases,” the IAM said he “can’t comment” because the information is “confidential.” The FAC accepted that and moved on.
The June 30, 2026 quarterly FWA report shows 14 new tips in that quarter alone, roughly 20 percent of all tips received since the program began in 2021. Activity is rising, and the FAC should ask for another status report and not accept evasive answers.
Confidentiality. Government Code section 53087.6, which the City cites, protects the identities of the hotline caller and the employee reported, as the City applies it. It does not make secret the categories of cases, such as theft, fraud, wasteful spending, or bribery. The City’s own Fraud, Waste and Abuse policy (Council Policy 4210) says the IAM’s quarterly report “will detail the type of issues that were received without disclosing the confidential nature of the case.”
Independence. The Internal Audit Framework attached to that policy states that the IAM reports “to the City Manager through the Chief Financial Officer.” State law requires city auditors to follow standards under which auditors “should be independent of the activities they audit” (Gov. Code § 1236). How can an auditor who reports to the executives whose departments are being audited be independent? Further, how could he independently review a complaint against the City Manager, the CFO, or the City Attorney?
Closing cases. The same lack of independence shapes how cases end. The same management group receives complaints, decides how to handle them, and closes a case when it finds the resolution “sufficient.” The policy defines no criteria for“sufficient” and provides no review outside management. With no written standard and no outside check, a case can be closed whether or not the investigation was thorough, and no one outside management can tell the difference. That is why “all cases have been reviewed and closed” tells the FAC nothing about whether the job was done well.
Qualifications. The Senior Management Analyst class requires a bachelor’s degree in public administration and four years of analytical experience. It requires no audit experience or CPA, CIA, or CFE credential. Yet the Framework promises “professional certifications.” As of late September 2026, the IAM’s public LinkedIn profile lists no audit certification. If he holds one, the City can say so. If not, the City should explain how the position meets its own Framework.
A correction. The audio of the September 2025 meeting shows FAC members described me as a “forceful and persistent” advocate of the FWA system. That is only partly accurate. I advocated for the independently managed system recommended by the City’s former internal audit firm, Moss Adams LLP. In my view, the management-run program operating today departs from that recommendation, and I do not support it.
Will the FAC require an updated status report and press for real answers? Residents are watching.
Les Greenberg, Esquire
