INTRADEPARTMENTAL CORRESPONDENCE March 22, 2013 14.2 TO: The Honorable Board of Police Commissioners FROM: Chief of Police SUBJECT: COMMERCIAL CRIMES DIVISION COMMAND ACCOUNTABILITY PERFORMANCE AUDIT (IAID NO. 12-089) RECOMMENDED ACTIONS 1. That the Board of Police Commissioners REVIEW and APPROVE the attached. 2. That the Board of Police Commissioners REVIEW and APPROVE the attached Executive Summary thereto. DISCUSSION Pursuant to the Annual Audit and Inspection Plan, Fiscal Year 2012/13, Internal Audits and Inspections Division Conducted the Commercial Crimes Division, Command Accountability. If additional information regarding this audit is required, please contact Gerald L. Chaleff, Special Assistant for Constitutional Policing, at (213) 486-8730. Respectfully, CHARLIE BECK Chief of Police Attachments
LOS ANGELES POLICE DEPARTMENT COMMERCIAL CRIMES DIVISION COMMAND ACCOUNTABILITY PERFORMANCE AUDIT (IAID NO. 12-089) Conducted by INTERNAL AUDITS & INSPECTIONS DIVISION CHARLIE BECK Chief of Police FY 2012/2013
COMMERCIAL CRIMES DIVISION COMMAND ACCOUNTABILITY PERFORMANCE AUDIT Second Quarter, Fiscal Year 2012/13 EXECUTIVE SUMMARY... i PURPOSE... 1 BACKGROUND... 1 OBJECTIVES, SCOPE AND METHODOLOGY... 1 SUMMARY OF FINDINGS... 3 DETAILED FINDINGS... 3 Objective No. 1 Evaluation of Arrest Reports... 3 Objective No. 1(a) Articulation of Reasonable Suspicion and Probable Cause to Arrest... 3 Objective No. 1(b) Articulation of Search and Seizure... 4 Objective No. 1(c) Admonition of Miranda Rights... 5 Objective No. 1(d) Distribution of Marsy's Rights Card... 5 Objective No. 2 Evaluation of Search/Ramey Warrant Packages... 6 Objective No. 2(a) Completeness of the Warrant Tracking Logs... 6 Objective No. 2(b) Legality of Search Warrant... 6 Objective No. 2(c) Magistrate Approval of Search/Ramey Warrant... 7 Objective No. 3 Supervisory Oversight... 7 Objective No. 3(a) Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC... 7 Objective No. 3(b) Evaluation of the Supervisory Releases 849(b)(1) PC/825 PC... 8 Objective No. 3(c) Evaluation of Case Categorizations... 9 Objective No. 3(d) Completion of Civilian Performance Evaluations... 10 ACTION TAKEN... 10
EXECUTIVE SUMMARY COMMERCIAL CRIMES DIVISION COMMAND ACCOUNTABILITY PERFORMANCE AUDIT Conducted by Internal Audits and Inspections Division Second Quarter, Fiscal Year 2012/13 PURPOSE In accordance with the Internal Audits and Inspections Division (IAID) fiscal year (FY) 2012/13 Annual Audit and Inspection Plan, IAID conducted a Commercial Crimes Division (CCD) Command Accountability (CAPA). This audit is performed to determine if the CCD operation is in adherence with Los Angeles Police Department (Department) policies and procedures, as well as other established criteria set forth by State and federal guidelines. This audit is intended to be used as a management tool to provide timely and useful feedback to the CCD commanding officer (CO) related to specific detective procedures. BACKGROUND Commercial Crimes Division was established in May 2003 with the merger of Burglary Auto Theft Division and Financial Crimes Division. There are seven sections in CCD: Burglary Special Section; Commercial Auto Theft Section; Fraud Section; Metropolitan Financial Section; West/Valley Financial Section; Taskforce for Regional Auto Theft Prevention (TRAP); and Administrative Section. Commercial Crimes Division can be categorized into two main areas of investigation: The Burglary Special and Auto Theft Section and Financial Crimes Section. The Burglary Special and Auto Theft Section provides logistical, technical and investigative support to Area detectives, and have primary investigative responsibility on certain select burglary, theft, auto theft, and robbery crimes on a Citywide basis. In addition, these sections are responsible for enforcing State law and Police Commission rules and regulations governing pawnshops, junk dealers, and any other business handling secondhand merchandise. The Financial Crimes Section is tasked with the Citywide investigative responsibility for all forgery and identity theft-related crimes. OBJECTIVES, SCOPE AND METHODOLOGY Department policies and procedures established the objectives for this audit as follows: Objective No. 1 Evaluation of Arrest Reports Objective No. 1(a) - Articulation of Reasonable Suspicion and Probable Cause to Arrest Objective No. 1(b) - Articulation of Search and Seizure Objective No. 1(c) - Admonition of Miranda Rights Objective No. 1(d) - Distribution of Marsy's Rights Card Objective No. 2 Evaluation of Search/Ramey Warrant Packages Objective No. 2(a) - Completeness of the Warrant Tracking Logs Objective No. 2(b) - Legality of Search Warrant Objective No. 2(c) - Magistrate Approval of Search/Ramey Warrant
Commercial Crime Division Command Accountability Executive Summary Page ii of ii Objective No. 3 Supervisory Oversight Objective No. 3(a) - Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC Objective No. 3(b) - Evaluation of the Supervisory Releases 849(b)(1) PC/825 PC Objective No. 3(c) - Evaluation of Case Categorizations Objective No. 3(d) - Completion of Civilian Performance Evaluations SUMMARY OF FINDINGS The following table summarizes findings for each objective. Objective No 1. Evaluation of Arrest Reports Table No. 1 Summary of Audit Description of Audit Objectives Total Number Reviewed Total Number Met the Standards Compliance Rate 1( a.) Articulation of Reasonable Suspicion and Probable Cause to Arrest 36 36 100% 1(b) Articulation of Search and Seizure 36 36 100% 1(c) Admonition of Miranda Rights 36 36 100% 1(d) Distribution of Marsy's Rights Card 29 29 100% 2. Evaluation of Search/Ramey Warrant Packages 2(a) Completeness of the Warrant Tracking Logs 7 7 100% 2(b) Legality of Search Warrant 7 7 100% 2(c) Magistrate Approval of Search/Ramey Warrant 7 7 100% 3. Supervisory Oversight 3(a) Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC 21 13 62% 1, 1 Evaluation of the Supervisory Releases 3( ' 849(b)(1) PC/825 PC 25 22 88% 3(c) Evaluation of Case Categorizations 59 57 97% 3(d) 1 Completion of Civilian Performance Evaluations 10 10 100% ACTION TAKEN Internal Audits and Inspections Division presented the audit report and findings to the CO, CCD Director, Office of Special Operations, and the CO, Detective Bureau, who expressed general agreement with the findings.
COMMERCIAL CRIMES DIVISION COMMAND ACCOUNTABILITY PERFORMANCE AUDIT Conducted by Internal Audits and Inspections Division Second Quarter, Fiscal Year 2012/13 PURPOSE In accordance with the Internal Audits and Inspections Division (IAID) fiscal year (FY) 2012/13 Annual Audit and Inspection Plan, IAID conducted a Commercial Crimes Division (CCD) Command Accountability (CAPA). This audit is performed to determine if the CCD operation is in adherence with Los Angeles Police Department (Department) policies and procedures, as well as other established criteria set forth by State and federal guidelines. This audit is intended to be used as a management tool to provide timely and useful feedback to the CCD commanding officer (CO) related to specific detective procedures. BACKGROUND Commercial Crimes Division was established in May 2003 with the merger of Burglary Auto Theft Division and Financial Crimes Division. There are seven sections in CCD: Burglary Special Section; Commercial Auto Theft Section; Fraud Section; Metropolitan Financial Section; West/Valley Financial Section; Taskforce for Regional Auto Theft Prevention (TRAP); and Administrative Section. Commercial Crimes Division can be categorized into two main areas of investigation: The Burglary Special and Commercial Auto Theft Section and Financial Crimes Section. The Burglary Special and Commercial Auto Theft Section provides logistical, technical and investigative support to Area detectives, and have primary investigative responsibility on certain select burglary, theft, auto theft, and robbery crimes on a Citywide basis. In addition, these sections are responsible for enforcing State law and Police Commission rules and regulations governing pawnshops, junk dealers, and any other businesses handling secondhand merchandise. The Financial Crimes Section is tasked with the Citywide investigative responsibility for all forgery and identity theft-related crimes. OBJECTIVES, SCOPE AND METHODOLOGY Department policies and procedures established the objectives for this audit as follows: Objective No. 1 Evaluation of Arrest Reports Objective No. 1(a) - Articulation of Reasonable Suspicion and Probable Cause to Arrest Objective No. 1(b) - Articulation of Search and Seizure Objective No. 1(c) - Admonition of Miranda Rights Objective No. 1(d) - Distribution of Marsy's Rights Card Objective No. 2 Evaluation of Search/Ramey Warrant Packages Objective No. 2(a) - Completeness of the Warrant Tracking Logs Objective No. 2(b) - Legality of Search Warrant Objective No. 2(c) - Magistrate Approval of Search/Ramey Warrant
Page 2 of 10 Objective No. 3 Supervisory Oversight Objective No. 3(a) - Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC Objective No. 3(b) - Evaluation of the Supervisory Releases 849(b)(1) PC/825 PC Objective No. 3(c) - Evaluation of Case Categorizations Objective No. 3(d) - Completion of Civilian Performance Evaluations For the purpose of this audit, IAID excluded TRAP since it mainly performs investigations with other agencies. Internal Audits and Inspections Division identified the following populations for this audit: Objective No. 1- Evaluation of Arrest Reports: IAID obtained arrests made by the CCD detectives from January 2012 to September 2012, and selected a statistically valid sample to determine the compliance with the objective; Objective No. 2 - Evaluation of Search/Ramey Warrant Packages: IAID obtained CCD search warrant tracking logs and search warrant packages served in September 2012, and reviewed all packages to determine the compliance with the objective; Objectives Nos. 3(a) and 3(b) - Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC and Evaluation of the Supervisory Releases 849(b)(1) PC/825 PC, IAID identified arrest made by CCD in September 2012 with disposition of 17(b)(4)PC - Supervisory Bypass and 849(b)(1) PC/825 PC - Supervisory Releases, and selected a statistically valid sample to determine the compliance with the objective; Objective No. 3(c) - Evaluation of Case Categorizations, IAID identified all Category Two cases generated in September 2012 by CCD, and selected a statistically valid sample to determine the compliance with the objective; and, Objective No. 3(d) - Completion of Civilian Performance Evaluations, IAID identified all civilian employees in CCD and reviewed all their employee personnel packages. This section is intentionally left blank.
Page 3 of 10 SUMMARY OF FINDINGS The following table summarizes findings for each objective. Objective No 1. Evaluation of Arrest Reports Table No. 2 Summary of Audit Description of Audit Objectives Total Number Reviewed Total Number Met the Standards Compliance Rate Articulation of Reasonable Suspicion and 1( 1 a Probable Cause to Arrest 36 36 100% 1(b) Articulation of Search and Seizure 36 36 100% 1(c) Admonition of Miranda Rights 36 36 100% 1(d) Distribution of Marsy's Rights Card 29 29 100% 2. Evaluation of Search/Ramey Warrant Packages 2(a) Completeness of the Warrant Tracking Logs 7 7 100% 2(b) Legality of Search Warrant 7 7 100% 2(c) Magistrate Approval of Search/Ramey Warrant 7 7 100% 3. Supervisory Oversight 1 3(a) Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC 21 13 62% 3( hl Evaluation of the Supervisory Releases ' ) 849(b)(1) PC/825 PC 25 22 88% 3(c) Evaluation of Case Categorizations 59 57 97% ( ) 3sci' Completion of Civilian Performance Evaluations 10 10 100% DETAILED FINDINGS Objective No. 1 Evaluation of Arrest Reports This audit objective included the review of arrest packages completed by all personnel assigned to CCD during the audit time period. The arrest packages were evaluated to determine whether they included articulation of legal sufficiency for actions taken, and whether they contained evidence of significant deviation from Department policies and procedures. Objective No. 1(a) Articulation of Reasonable Suspicion and Probable Cause to Arrest "Reasonable suspicion for detention" was measured by the standards described in the California Peace Officers Legal Sourcebook as "a set of specific and articulable facts that lead an officer to
Page 4 of 10 reasonably believe that a crime is occurring, is about to occur, or has occurred, and that the person detained is connected to that activity which is criminal in nature." "Probable Cause to Arrest" was measured by the standards described in the California Peace Officers Legal Sourcebook as "a set offacts that would lead an officer of similar training and experience to form an honest and strong belief that the individual has committed a crime, based on the totality of the circumstances." Internal Audits and Inspections Division reviewed the 36 arrest packages to determine whether each report sufficiently articulated the legal basis for all actions taken (i.e., detentions, arrests, and searches). Arrest packages that articulated the aforementioned criteria and procedures met the standards for this objective. Each (100%) of the 36 packages met the standards for this objective. Objective No. 1(b) Articulation of Search and Seizure Department Manual, Volume 4/217, Search of Suspects and Arrestees, states, "When the rules of search and seizure permit, an arrestee shall be thoroughly searched as soon as practicable." The Fourth Amendment of the United States Constitution protects people against unreasonable searches. As such, the legality of seizure of evidence or property was based on the articulated existence of one of the following: consent, incident to arrest, probable cause, or exigent circumstances. Arrest packages were reviewed to evaluate the legality of the search and seizure, including the booking search. Arrest packages that articulated the search authority and articulated the legal justification for the seizure met the standards for this objective. Each (100%) of the 36 packages met the standards for this objective. This section is intentionally left blank.
Page 5 of 10 Objective No. 1(c) Admonition of Miranda Rights Department Manual, Volume 4/202.10, Interrogation of Suspects Admonition of Miranda Rights states, "Interrogation Officers Responsibilities. When officers are conducting a custodial interrogation, the following procedures shall be followed: Officers shall document the suspect's responses to the Miranda admonition in the appropriate report." Arrest packages were reviewed for the overall chronology of arrest events specifically examining whether a detainee was interrogated regarding his/her participation in criminal activity. Arrest packages were also reviewed for evidence of Miranda rights violations. Arrest packages that contained no evidence of Miranda rights violations met the standards for this objective. Each (100%) of the 36 packages met the standards for this objective. Objective No. 1(d) Distribution of Marsy's Rights Card Special Order No. 43, August 24, 2009, Implementation of Marsy's Law; Investigative Report, Form 03.01.00 Revised; and Arrest Report, Form 05.02.00 Revised, states, "Officers completing any crime report (e.g., Investigative Report; Stolen Vehicle Report, CHP Form 180; etc.) or combined crime/arrest report (e.g., Arrest Report) shall provide the victim(s) a Marsy's Rights Card." Arrest packages were reviewed to determine whether the officers documented the distribution of the Marsy's Right card (card) to the victim(s) on the Investigative Report, Form 03.01.00, Stolen Vehicle Report, CHP Form 180, or combined crime/arrest report.' The arrest packages that indicated the distribution of the Marsy's Rights Card when required met the standards for this objective. Twenty-nine arrest packages identified victims. Each (100%) of the 29 packages met the standards for this objective. The arrests made by the other agencies and other Department divisions were excluded from the test work.
Page 6 of 10 Objective No. 2 Evaluation of Search/Ramey Warrant Packages Objective No. 2(a) Completeness of the Warrant Tracking Logs Department policy and procedure requires that each Area and specialized division maintain a log listing each search warrant, indicating where a copy of such warrant is maintained, the affiant who applied for the warrant, and the approving supervisor for the warrant.2 Internal Audits and Inspections Division reviewed CCD warrant tracking logs for the month of September 2012 to determine if they were completed and maintained as required. Warrant Tracking Logs that identify the affiant, the location of the search warrant, the approving supervisor, and the CO met the standards for this objective. Each (100%) of the seven warrant packages met the standards for this objective. Objective No. 2(b) Legality of Search Warrant Legal basis for the warrant was defined as the articulation of probable cause pursuant to Penal Code Section 1525. 3 The Fourth Amendment of the United States Constitution protects people against unreasonable searches. As such, Department personnel are required to document the legal basis for conducting searches which include the following: search warrants, probable cause, incident to arrest, consent, or exigent circumstances. There were seven search warrants served in September 2012. Internal Audits and Inspections Division reviewed all packages to determine whether the affidavit articulated the probable cause as required by the Department policies. Each (100%) of the seven warrant packages reviewed met the standards for this objective. 2 See Department Manual Volume 4/472.10 and Warrant Tracking Log, Form 08.17.05 Completion Instructions. 3 See Department Manual Section 4/742.10.
Page 7 of 10 Objective No. 2(c) Magistrate Approval of Search/Ramey Warrant Department Manual, Volume 4/742.10, Search Warrant and Probable Cause Arrest Procedures, states, "... all Department personnel involved in the service (including the planning and debriefing) of a search or Ramey warrant shall comply with the instructions set forth in the Search Warrant Service Procedures Guide, prepared by Investigative Analysis Unit, Detective Bureau. Department personnel shall follow these guidelines when preparing, obtaining, serving, and returning a search warrant." Procedures The warrant packages were reviewed to determine if they were properly approved by a magistrate prior to the service of the search warrant. Packages that contained evidence of a signature by the magistrate, prior to the service of the warrant, met the standards for this objective. Each (100%) of the seven search warrant packages met the standards for this objective. Objective No. 3 Supervisory Oversight Objective No. 3(a) Evaluation of Supervisory Bypass/Referrals 17(b)(4) PC Department Manual, Volume 4/720.36 17(b)(4) PC. Referrals to the City Attorney's Office, states, "Due to procedural changes implemented by the new Inter-Agency Operational Agreement between the Office of the Los Angeles County District Attorney (DA), the Office of the Los Angeles City Attorney (CA), and the Los Angeles County Prosecutors Association, the aforementioned entities have developed new guidelines for Penal Code (PC) Section 17(b)(4) referrals outlined in the Inter-Agency Operational Agreement, 17(b)(4) PC Referrals, Schedule I Under the agreement, the 17(b)(4) PC bypass cases listed on Schedule I also known as "wobblers," shall be referred directly to the CA for filing, provided they meet the criteria listed on the schedule." Internal Audits and Inspections Division reviewed the 21 arrest packages in which a 17(b)(4) PC, Supervisory Bypass/Referral was utilized for the month of September 2012 to determine whether supervisors used the Supervisory Bypass/Referral procedures in accordance with Department policy, procedures, and Chief of Detectives Notice, October 13, 2011. Thirteen (62%) of the 21 17(b)(4) PC, Supervisory Bypass/Referrals, met the standards for this objective. The remaining eight cases are detailed below:
Page 8 of 10 Booking Nos. 3109805, 3215684, 3076343, 3264426, 3117056, and 3059383 These cases involved 530.5(a)PC, Identity Theft. Based on Chief of Detectives Notice, October 13, 2011, this charge did not qualify for a direct referral to the City Attorney's office. These cases should have been initially presented to the Los Angeles County District Attorney's Office for filing consideration. Booking No. 3093536 This case involved an arrest for 529 PC, Impersonation of Another. Based on Chief of Detectives Notice, October 13, 2011, this charge did not qualify for a direct referral to the City Attorney's office. This case should have been initially presented to the Los Angeles County District Attorney's Office for filing consideration. Booking No. 3155168 This case involved an arrest for 475(c) PC, Possession of Fraudulent Check. The suspect's criminal history indicted he had several prior felony convictions. Based on Chief of Detectives Notice, October 13, 2011, this case did not qualify for a direct referral to the City Attorney's office. This case should have been initially presented to the Los Angeles County District Attorney's Office for filing consideration. Management's Response Internal Audits and Inspections Division reviewed 21 Bypass Referral investigations and found that 13 were in compliance and eight were out of compliance with Department policy, which equated to 62 percent. In reviewing the eight cases, CCD noted that all except for one of the cases were assigned to Metropolitan Financial Section (MFS) and Valley Financial Section (VFS). As a result of said findings, CCD personnel were provided refresher training in the Department policy of 17(b)(4) PC, Bypass Referral to the Los Angeles City Attorney's Office Objective No. 3(b) Evaluation of the Supervisory Releases 849(b)(1) PC1825 PC Detective Operations Manual, Volume 1/353.14, 825 PC, states, "When a suspect has been released under 825 PC, a Follow-up Investigation, Form 3.14, shall be completed within ten working days from the date of case assignment." Detective Operations Manual, Volume 1/256.03, 849(b)(1) PC, states, "When an adult is arrested without a case being presented to a prosecuting agency because there are insufficient grounds for making a criminal complaint, or the arrestee is being released pending further investigation, the 849(b)(1) PC box is checked....the reason for the release shall also be checked." Internal Audits and Inspections Division reviewed 25 arrest packages in which 849(b)(1) PC/825 PC was utilized. For 849(b)(1) PC, IAID reviewed the arrest packages to determine whether required documentation, such as reason for release was inside the package. For 825 PC, IAID reviewed the arrest packages to determine whether a Follow-up Investigation, Form 3.14, was completed within ten working days from the date of case assignment.
Page 9 of 10 Twenty-two (88%) of the 25 packages reviewed met the standards for this objective. The remaining three packages that did not meet the standards for this objective are detailed below: Booking No. 3079153 The arrestee was released for 825 PC. The Follow-up Investigation, Form 3.14, was not completed in ten working days as required by Department Manual. Booking Nos. 3120052 and 3120047 The arrestee was released for 825 PC. However, there was no Follow-up Investigation, Form 3.14, in the packages. Management's Response Internal Audits and Inspections Division reviewed 25 arrest packages in which 849(b)(1) PC/825 PC were utilized. Of the 25 cases audited, 22 were in compliance which led to three out of compliance with Department policy, which equated to 88 percent in compliance. In reviewing the three cases, CCD noted that all except for one of the cases were assigned to MFS and VFS. As a result of said findings, CCD personnel were provided refresher training in the Department policy of evaluation of the supervisory release. Objective No. 3(c) Evaluation of Case Categorizations Detective Operations Manual, Volume 11121.00, Case Categorization, states, "To determine whether a report falls within Category One or Two, a detective supervisor shall review the original report and any accompanying reports for specific circumstances or significant facts which may demand further investigation and/or may lead to solving the crime. When making a determination the detective supervisor should consider, but not be limited to the following: Suspect's Identity" Internal Audits and Inspections Division reviewed 59 Category Two cases to determine whether any suspect's identity, such as named suspect or associate, physical evidence that could identify the suspect, possible address or location which the suspect frequents, and victim/witness could possibly identify suspect from a live or photographic show-up. Fifty-seven (97%) of the 59 cases reviewed met the standards for this objective. The remaining two packages that did not meet the standards for this objective are detailed below:
Page 10 of 10 DR No. 122115243 This was a forgery case. A possible suspect's name and address was identified. This case should be classified as Category One and a follow-up should be conducted. DR. No. 120200633 This was a forgery case. A possible suspect's name was identified. This case should be classified as Category One and a follow-up should be conducted. Management's Response There was no response from the management. Objective No. 3(d) Completion of Civilian Performance Evaluations Department Manual Section 3/760.70, Civilian Performance Evaluations (CPEs) states, "Service ratings shall be made annually on all civilian employees on an Employee Evaluation Report, Form PDAS 28. A Training Evaluation and management System II (TEAMS II) report shall be provided to each employee in conjunction with the service of the employee 's annual performance evaluation report." Internal Audits and Inspections Division examined ten civilian employee personnel folders to determine whether an employee Evaluation Report, Form PDAS 28 was completed for the past year. Each (100%) of the ten civilian employee personnel files had the most recent Employee Evaluation Report, Form PDAS 28. ACTION TAKEN Internal Audits and Inspections Division presented the audit report and findings to the CO, CCD Director, Office of Special Operations, and the CO, Detective Bureau, who expressed general agreement with the findings.
INTRADEPARTMENTAL CORRESPONDENCE January 29, 2013 8.7 TO: Commanding Officer, Internal Audits and Inspections Division FROM: Commanding Officer, Commercial Crimes Division SUBJECT: COMMAND ACCOUNTABILITY PERFORMANCE AUDIT RESPONSE, JANUARY 29, 2013 Commercial Crimes Division (CCD) is in general agreement with all of the findings identified in the Command Accountability Report. In each case where CCD was deemed out of compliance, the concerned personnel were provided refresher training in the following two areas. Those areas were in the evaluation of supervisory bypass/referral procedures and evaluation of supervisory releases. The performance areas deemed out of compliance and/or required action are listed below: Objective No. 3(a) Evaluation of Supervisory Bypass/Referrals, specifically, cases that were inappropriately bypassed to the Los Angeles City Attorney's Office for filing consideration. Internal Audits and Inspections Division reviewed 21 Bypass Referral investigations and found that thirteen were in compliance and eight were out of compliance with Department Policy which equated to 62 percent. In reviewing the eight cases CCD noted that all except for one of the cases were assigned to Metropolitan Financial Section (MFS) and Valley Financial Section (VFS). As a result of said findings, CCD personnel, was provided refresher training in the Department policy of 17(b) (a) Penal Code, Bypass Referrals to the Los Angeles City Attorney's Office. Objective No. 3(b) Evaluation of the Supervisory Releases 849(b) (1) PC/ 825 PC Internal Audits and Inspections Division reviewed 25 arrest packages in which 849(b) (1) PC/ 825 PC were utilized. Of the 25 cases audited 22 were in compliance which led to three out of compliance with Department Policy which equated to 88 percent. In reviewing the three cases CCD noted that all the cases were assigned to MFS and VFS. As a result of said findings, CCD personnel, was provided refresher training in the Department policy of evaluation of the supervisory releases. If you have any quest ans please contact Detective Daniel Mendoza, CCD, at (213) 486-8783. BILL WILLIAMS, Captain Commanding Officer Commercial Crimes Division