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Response synthesis and audit

Responses to Banning: A City Alarmingly Mismanaged

Final supplied positions, implementation claims, future actions and stated refusals are attributed separately to the responding agencies or signatories.

Official response PDFOfficial report PDF

Response by See per-item agency attribution

80

Addressed

5

Partially addressed

0

Not addressed

0

Unclear

County's stated disposition

These categories reflect the County's response to each recommendation, separate from this audit's assessment.

20

Implemented

20

Will be implemented

0

Requires further analysis

5

Will not be implemented

0

Unclear

How to read this audit

Assessment concerns statutory response clarity, explanation, coverage and traceability, not which party is factually correct or whether a legal violation occurred. Implementation is an agency claim unless explicitly established otherwise. No inference of nonresponse or lateness follows a source gap. Finding clarity scores are separate from coverage and support; recommendations have dispositions, not finding scores. Signed August 14 cover and complete 35-page packet independently reviewed, including the copied report. Shared substantive wording is attributed to this signatory; it is not independent corroboration or a new jury investigation. Response physical pages 22–35 are used, not printed attachment pages 2–15. Signed August 14 cover and complete 35-page packet independently reviewed, including the copied report. Shared substantive wording is attributed to this signatory; it is not independent corroboration or a new jury investigation. Response physical pages 22–35 are used, not printed attachment pages 2–15. Signed August 14 cover and complete 35-page packet independently reviewed, including the copied report. Shared substantive wording is attributed to this signatory; it is not independent corroboration or a new jury investigation. Response physical pages 22–35 are used, not printed attachment pages 2–15. Signed August 14 cover and complete 35-page packet independently reviewed, including the copied report. Shared substantive wording is attributed to this signatory; it is not independent corroboration or a new jury investigation. Response physical pages 22–35 are used, not printed attachment pages 2–15. Signed August 14 cover and complete 35-page packet independently reviewed, including the copied report. Shared substantive wording is attributed to this signatory; it is not independent corroboration or a new jury investigation. Response physical pages 22–35 are used, not printed attachment pages 2–15.

Commitments

Actions stated in the response

These are commitments extracted from the County's response. They describe what the response says will happen; they do not verify that implementation occurred.

50

Extracted commitments

35

Definite or bounded timing

15

Conditional timing

0

No timeframe

MAYOR-R1 · Exact date

Complete the described review of BEU financial and ledger activity.

2027-01-01

MAYOR-R2 · Bounded timeframe

Review peer municipal-electric accounting practices before the stated annual financial report.

Before publication of the FY 2025–2026 ACFR; no calendar date supplied.

MAYOR-R3 · Bounded timeframe

Review allocation-plan appropriateness annually during the budget process.

Annually as part of the annual budget process; no calendar completion date supplied.

MAYOR-R4 · Conditional timing

Pursue the described budget, internal-control and annual-report improvements.

Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified.

MAYOR-R5 · Conditional timing

Pursue the alternative billing-system upgrade.

Estimated July 2027 phase; not a guaranteed completion day.

MAYOR-R5 · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Estimated November 2027 phase; not a guaranteed completion day.

MAYOR-R6 · Exact date

Prepare the described comprehensive onboarding and offboarding program.

2026-11-01

MAYOR-R6 · Exact date

Prepare a detailed organizational-culture program for implementation.

2027-01-01

MAYOR-R7 · Exact date

Update the described HR and Finance policies.

2026-10-01

MAYOR-R7 · Exact date

Deliver the training described by the response heading.

2027-11-01

PROTEM-R1 · Exact date

Complete the described review of BEU financial and ledger activity.

2027-01-01

PROTEM-R2 · Bounded timeframe

Review peer municipal-electric accounting practices before the stated annual financial report.

Before publication of the FY 2025–2026 ACFR; no calendar date supplied.

PROTEM-R3 · Bounded timeframe

Review allocation-plan appropriateness annually during the budget process.

Annually as part of the annual budget process; no calendar completion date supplied.

PROTEM-R4 · Conditional timing

Pursue the described budget, internal-control and annual-report improvements.

Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified.

PROTEM-R5 · Conditional timing

Pursue the alternative billing-system upgrade.

Estimated July 2027 phase; not a guaranteed completion day.

PROTEM-R5 · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Estimated November 2027 phase; not a guaranteed completion day.

PROTEM-R6 · Exact date

Prepare the described comprehensive onboarding and offboarding program.

2026-11-01

PROTEM-R6 · Exact date

Prepare a detailed organizational-culture program for implementation.

2027-01-01

PROTEM-R7 · Exact date

Update the described HR and Finance policies.

2026-10-01

PROTEM-R7 · Exact date

Deliver the training described by the response heading.

2027-11-01

WALLACE-R1 · Exact date

Complete the described review of BEU financial and ledger activity.

2027-01-01

WALLACE-R2 · Bounded timeframe

Review peer municipal-electric accounting practices before the stated annual financial report.

Before publication of the FY 2025–2026 ACFR; no calendar date supplied.

WALLACE-R3 · Bounded timeframe

Review allocation-plan appropriateness annually during the budget process.

Annually as part of the annual budget process; no calendar completion date supplied.

WALLACE-R4 · Conditional timing

Pursue the described budget, internal-control and annual-report improvements.

Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified.

WALLACE-R5 · Conditional timing

Pursue the alternative billing-system upgrade.

Estimated July 2027 phase; not a guaranteed completion day.

WALLACE-R5 · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Estimated November 2027 phase; not a guaranteed completion day.

WALLACE-R6 · Exact date

Prepare the described comprehensive onboarding and offboarding program.

2026-11-01

WALLACE-R6 · Exact date

Prepare a detailed organizational-culture program for implementation.

2027-01-01

WALLACE-R7 · Exact date

Update the described HR and Finance policies.

2026-10-01

WALLACE-R7 · Exact date

Deliver the training described by the response heading.

2027-11-01

MILLER-R1 · Exact date

Complete the described review of BEU financial and ledger activity.

2027-01-01

MILLER-R2 · Bounded timeframe

Review peer municipal-electric accounting practices before the stated annual financial report.

Before publication of the FY 2025–2026 ACFR; no calendar date supplied.

MILLER-R3 · Bounded timeframe

Review allocation-plan appropriateness annually during the budget process.

Annually as part of the annual budget process; no calendar completion date supplied.

MILLER-R4 · Conditional timing

Pursue the described budget, internal-control and annual-report improvements.

Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified.

MILLER-R5 · Conditional timing

Pursue the alternative billing-system upgrade.

Estimated July 2027 phase; not a guaranteed completion day.

MILLER-R5 · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Estimated November 2027 phase; not a guaranteed completion day.

MILLER-R6 · Exact date

Prepare the described comprehensive onboarding and offboarding program.

2026-11-01

MILLER-R6 · Exact date

Prepare a detailed organizational-culture program for implementation.

2027-01-01

MILLER-R7 · Exact date

Update the described HR and Finance policies.

2026-10-01

MILLER-R7 · Exact date

Deliver the training described by the response heading.

2027-11-01

MANAGER-R1 · Exact date

Complete the described review of BEU financial and ledger activity.

2027-01-01

MANAGER-R2 · Bounded timeframe

Review peer municipal-electric accounting practices before the stated annual financial report.

Before publication of the FY 2025–2026 ACFR; no calendar date supplied.

MANAGER-R3 · Bounded timeframe

Review allocation-plan appropriateness annually during the budget process.

Annually as part of the annual budget process; no calendar completion date supplied.

MANAGER-R4 · Conditional timing

Pursue the described budget, internal-control and annual-report improvements.

Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified.

MANAGER-R5 · Conditional timing

Pursue the alternative billing-system upgrade.

Estimated July 2027 phase; not a guaranteed completion day.

MANAGER-R5 · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Estimated November 2027 phase; not a guaranteed completion day.

MANAGER-R6 · Exact date

Prepare the described comprehensive onboarding and offboarding program.

2026-11-01

MANAGER-R6 · Exact date

Prepare a detailed organizational-culture program for implementation.

2027-01-01

MANAGER-R7 · Exact date

Update the described HR and Finance policies.

2026-10-01

MANAGER-R7 · Exact date

Deliver the training described by the response heading.

2027-11-01

Item-by-item review

Findings and recommendations

Assessments describe whether the response engages each cited item. Finding scores separately describe statutory-elements completeness under California Penal Code § 933.05(a) and public usefulness. They do not independently verify the response or constitute a legal conclusion.

Showing 85 of 85 items

finding · MAYOR-F1

The Banning Electric Utility (BEU) went from a $31 million surplus in 2018, to a $9 million deficit in 2022.

Audit: Addressed

Response says

Partly disagrees; distinguishes fund balance, cash, adjustments and reconciliations.

Audit analysis

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Scoring confidence: high

Report page 14Response page 22
Discuss finding and response

finding · MAYOR-F2

Multiple sources have stated that the City of Banning may have transferred revenue from the BEU to the General Fund. These transfers would be in violation of Propositions 26 and 218 after Measure P was rejected by the voters in November 2018.

Audit: Addressed

Response says

Partly disagrees; denies recent unlawful transfers and does not resolve every older year.

Audit analysis

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Scoring confidence: high

Report page 14Response page 23
Discuss finding and response

finding · MAYOR-F3

The Cost Allocation Plan utilized from 2018 to present contains serious errors and lack internal controls.

Audit: Addressed

Response says

Partly disagrees; distinguishes current allocation work from historical weaknesses.

Audit analysis

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MAYOR-F4

Per Standard & Poor’s Global Rating Report, the electric system revenue bond rating has been downgraded from A- in 2007 to B (junk status) in 2026.

Audit: Addressed

Response says

Agrees, with dated rating history and fiscal context.

Audit analysis

Pages 25–26 cite S&P downgrade dates, late audited statements and financial pressures. These are specific traceable explanations, not an independent audit or verified forecast of recovery.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated S&P actions and identified reporting and financial issues support the explanation; agreement does not require a disagreement rationale.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MAYOR-F5

The City of Banning is currently experiencing a monumental billing crisis due to an antiquated billing system and failed software rollout.

Audit: Addressed

Response says

Partly disagrees; accepts the November 2024–April 2026 billing crisis but denies it continues and disputes the proposed fiscal-transfer connection.

Audit analysis

Pages 26–27 attribute the crisis to software purchase and rollout, claim current monthly billing and distinguish catch-up bills from double charging. July 14 payment-plan action is cited. These are agency explanations, not independently verified billing outcomes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

The disputed period and causal inference are explicit, with dated payment-plan and software-transition details.

Scoring confidence: high

Report page 14Response page 26
Discuss finding and response

finding · MAYOR-F6

The City of Banning has experienced a substantial turnover of essential personnel.

Audit: Addressed

Response says

Agrees, with recruitment, budget and strategic-plan context.

Audit analysis

Pages 27–28 acknowledge turnover and describe recruitment, planned initiatives and fiscal constraints. Named strategic-plan measures are traceable explanations, not independently verified staff retention results.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Agreement is explicit; the response names strategic planning and budget/recruitment mechanisms behind its explanation.

Scoring confidence: high

Report page 14Response page 27
Discuss finding and response

finding · MAYOR-F7

Human resources policies and procedures are outdated and not enforced, leaving the City vulnerable to litigation.

Audit: Addressed

Response says

Partly disagrees; accepts some policy-update needs and disputes nonenforcement.

Audit analysis

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Scoring confidence: high

Report page 14Response page 28
Discuss finding and response

finding · MAYOR-F8

The City of Banning is currently operating without a strategic plan.

Audit: Addressed

Response says

Disagrees that the City operates without a strategic plan.

Audit analysis

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Scoring confidence: high

Report page 14Response page 30
Discuss finding and response

recommendation · MAYOR-R1

Conduct a transparent audit of all BEU finances and ledger activity to determine if any fund transfers violated the terms of Propositions 26 and 218 after Measure P was defeated. Based on Findings: F-1, F-2, F-4 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Addressed

Response says

Will review the relevant accounting and ledger activity by January 1, 2027.

Audit analysis

The respondent describes a future review of the disputed transfers rather than an already completed audit or legal conclusion.

Extracted commitments

Complete the described review of BEU financial and ledger activity.

Responsible party
Banning Mayor Richard Royce
Timing
2027-01-01 · Exact date
Report page 15Response page 31

recommendation · MAYOR-R2

Distinctly separate the BEU financial data from other City departments by reviewing best practices of other cities that operate their own municipal electric utilities. Based on Findings: F-1, F-2, F-4 Implementation: December 31, 2026 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims financial separation already exists; promises a peer review before the FY 2025–2026 ACFR.

Audit analysis

Separate accounting is claimed as existing. The additional event-bounded comparison is future work, not proof that all requested best practices have been evaluated.

Extracted commitments

Review peer municipal-electric accounting practices before the stated annual financial report.

Responsible party
Banning Mayor Richard Royce
Timing
Before publication of the FY 2025–2026 ACFR; no calendar date supplied. · Bounded timeframe
Report page 15Response page 31

recommendation · MAYOR-R3

Manage Cost Allocation Plans to ensure current, accurate, and transparent documentation. Based on Finding: F-3 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims June 2026 implementation and promises annual allocation-plan review.

Audit analysis

The response claims the Finance Director implemented the recommendation in June 2026 and will review allocations annually during the budget process. It supplies no July 2027 review deadline.

Extracted commitments

Review allocation-plan appropriateness annually during the budget process.

Responsible party
Banning Mayor Richard Royce
Timing
Annually as part of the annual budget process; no calendar completion date supplied. · Bounded timeframe
Report page 15Response page 32

recommendation · MAYOR-R4

Improve the financial management practices beginning with immediately balancing the budget and bolstering internal control processes. Complete all annual financial reports on time. Based on Finding: F-1, F-3, F-4, F-5, F-8 Implementation: July 1, 2027 Financial Impact: Moderate

County: Will be implementedAudit: Addressed

Response says

Plans budget and control improvements, with qualified efforts toward annual reporting by July 1, 2027.

Audit analysis

Pages 32–33 describe an anticipated September budget action and efforts dependent on reporting/audit work. These are qualified plans, not an adopted balanced budget or a guarantee that all reports will be current.

Extracted commitments

Pursue the described budget, internal-control and annual-report improvements.

Responsible party
Banning Mayor Richard Royce
Timing
Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified. · Conditional timing
Report page 15Response page 32

recommendation · MAYOR-R5

Review, compare, and implement a newer software application including Cloud solutions to update the current billing system. Based on Finding: F-5 Implementation: Immediately Financial Impact: Moderate/High

County: Will not be implementedAudit: Addressed

Response says

Will not replace the underlying software as proposed; plans existing-system upgrades instead.

Audit analysis

The response explains cost, licensing and existing-system considerations and describes two alternative phases. Refusal is not reclassified as completed replacement.

Extracted commitments

Pursue the alternative billing-system upgrade.

Responsible party
Banning Mayor Richard Royce
Timing
Estimated July 2027 phase; not a guaranteed completion day. · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Responsible party
Banning Mayor Richard Royce
Timing
Estimated November 2027 phase; not a guaranteed completion day. · Conditional timing
Report page 15Response page 33

recommendation · MAYOR-R6

Initiate a comprehensive onboarding and offboarding program to include appropriate training, transfer of knowledge, and clarity for job responsibilities. Take all necessary steps to improve the culture through transparency, training and collaboration. Based on Finding: F-6 Implementation: Immediately Financial Impact: Low

County: Will be implementedAudit: Addressed

Response says

Will prepare onboarding/offboarding and organizational-culture programs.

Audit analysis

The response names November 1, 2026 and January 1, 2027 program-readiness targets, not implementation immediately as the jury proposed.

Extracted commitments

Prepare the described comprehensive onboarding and offboarding program.

Responsible party
Banning Mayor Richard Royce
Timing
2026-11-01 · Exact date

Prepare a detailed organizational-culture program for implementation.

Responsible party
Banning Mayor Richard Royce
Timing
2027-01-01 · Exact date
Report page 15Response page 34

recommendation · MAYOR-R7

Create a central policy location on SharePoint or similar program, organized by department, that is accessible and easy to locate. Update all policies and procedures to reflect current city, state, and federal guidelines and review and revise annually as needed. Enforce policies through staff training and accountability mechanisms. Based on Finding: F-6 and F-7 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Partially addressed

Response says

Claims SharePoint exists and promises policy updates and later training.

Audit analysis

The source image confirms October 1, 2026, not the OCR’s 2028, for policy updates; the heading gives November 1, 2027 for training. HR and Finance updates are described, but annual citywide review/enforcement scope is not fully specified.

Extracted commitments

Update the described HR and Finance policies.

Responsible party
Banning Mayor Richard Royce
Timing
2026-10-01 · Exact date

Deliver the training described by the response heading.

Responsible party
Banning Mayor Richard Royce
Timing
2027-11-01 · Exact date
Report page 16Response page 34

recommendation · MAYOR-R8

Promptly establish an impartial, thorough, and efficient investigation process for all harassment complaints utilizing qualified and trained personnel to ensure due process for every employee including elected officials. Based on Finding: F-6 and F-7 Implementation: Immediately Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims an impartial complaint-investigation process is implemented.

Audit analysis

The response cites qualified personnel and procedures. No independent review of individual harassment investigations is implied.

Report page 16Response page 35

recommendation · MAYOR-R9

Draft and implement a strategic plan to address all issues related to financial and personnel matters existing within the City of Banning. Based on Finding: F-4 and F-8 Implementation: Immediately Financial Impact: Low/Moderate.

County: ImplementedAudit: Addressed

Response says

Claims a strategic plan is implemented.

Audit analysis

The answer relies on the planning materials and history discussed under F8; a plan is not proof every financial or personnel action has been completed.

Report page 16Response page 35

finding · PROTEM-F1

The Banning Electric Utility (BEU) went from a $31 million surplus in 2018, to a $9 million deficit in 2022.

Audit: Addressed

Response says

Partly disagrees; distinguishes fund balance, cash, adjustments and reconciliations.

Audit analysis

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Scoring confidence: high

Report page 14Response page 22
Discuss finding and response

finding · PROTEM-F2

Multiple sources have stated that the City of Banning may have transferred revenue from the BEU to the General Fund. These transfers would be in violation of Propositions 26 and 218 after Measure P was rejected by the voters in November 2018.

Audit: Addressed

Response says

Partly disagrees; denies recent unlawful transfers and does not resolve every older year.

Audit analysis

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Scoring confidence: high

Report page 14Response page 23
Discuss finding and response

finding · PROTEM-F3

The Cost Allocation Plan utilized from 2018 to present contains serious errors and lack internal controls.

Audit: Addressed

Response says

Partly disagrees; distinguishes current allocation work from historical weaknesses.

Audit analysis

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · PROTEM-F4

Per Standard & Poor’s Global Rating Report, the electric system revenue bond rating has been downgraded from A- in 2007 to B (junk status) in 2026.

Audit: Addressed

Response says

Agrees, with dated rating history and fiscal context.

Audit analysis

Pages 25–26 cite S&P downgrade dates, late audited statements and financial pressures. These are specific traceable explanations, not an independent audit or verified forecast of recovery.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated S&P actions and identified reporting and financial issues support the explanation; agreement does not require a disagreement rationale.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · PROTEM-F5

The City of Banning is currently experiencing a monumental billing crisis due to an antiquated billing system and failed software rollout.

Audit: Addressed

Response says

Partly disagrees; accepts the November 2024–April 2026 billing crisis but denies it continues and disputes the proposed fiscal-transfer connection.

Audit analysis

Pages 26–27 attribute the crisis to software purchase and rollout, claim current monthly billing and distinguish catch-up bills from double charging. July 14 payment-plan action is cited. These are agency explanations, not independently verified billing outcomes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

The disputed period and causal inference are explicit, with dated payment-plan and software-transition details.

Scoring confidence: high

Report page 14Response page 26
Discuss finding and response

finding · PROTEM-F6

The City of Banning has experienced a substantial turnover of essential personnel.

Audit: Addressed

Response says

Agrees, with recruitment, budget and strategic-plan context.

Audit analysis

Pages 27–28 acknowledge turnover and describe recruitment, planned initiatives and fiscal constraints. Named strategic-plan measures are traceable explanations, not independently verified staff retention results.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Agreement is explicit; the response names strategic planning and budget/recruitment mechanisms behind its explanation.

Scoring confidence: high

Report page 14Response page 27
Discuss finding and response

finding · PROTEM-F7

Human resources policies and procedures are outdated and not enforced, leaving the City vulnerable to litigation.

Audit: Addressed

Response says

Partly disagrees; accepts some policy-update needs and disputes nonenforcement.

Audit analysis

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Scoring confidence: high

Report page 14Response page 28
Discuss finding and response

finding · PROTEM-F8

The City of Banning is currently operating without a strategic plan.

Audit: Addressed

Response says

Disagrees that the City operates without a strategic plan.

Audit analysis

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Scoring confidence: high

Report page 14Response page 30
Discuss finding and response

recommendation · PROTEM-R1

Conduct a transparent audit of all BEU finances and ledger activity to determine if any fund transfers violated the terms of Propositions 26 and 218 after Measure P was defeated. Based on Findings: F-1, F-2, F-4 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Addressed

Response says

Will review the relevant accounting and ledger activity by January 1, 2027.

Audit analysis

The respondent describes a future review of the disputed transfers rather than an already completed audit or legal conclusion.

Extracted commitments

Complete the described review of BEU financial and ledger activity.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
2027-01-01 · Exact date
Report page 15Response page 31

recommendation · PROTEM-R2

Distinctly separate the BEU financial data from other City departments by reviewing best practices of other cities that operate their own municipal electric utilities. Based on Findings: F-1, F-2, F-4 Implementation: December 31, 2026 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims financial separation already exists; promises a peer review before the FY 2025–2026 ACFR.

Audit analysis

Separate accounting is claimed as existing. The additional event-bounded comparison is future work, not proof that all requested best practices have been evaluated.

Extracted commitments

Review peer municipal-electric accounting practices before the stated annual financial report.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
Before publication of the FY 2025–2026 ACFR; no calendar date supplied. · Bounded timeframe
Report page 15Response page 31

recommendation · PROTEM-R3

Manage Cost Allocation Plans to ensure current, accurate, and transparent documentation. Based on Finding: F-3 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims June 2026 implementation and promises annual allocation-plan review.

Audit analysis

The response claims the Finance Director implemented the recommendation in June 2026 and will review allocations annually during the budget process. It supplies no July 2027 review deadline.

Extracted commitments

Review allocation-plan appropriateness annually during the budget process.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
Annually as part of the annual budget process; no calendar completion date supplied. · Bounded timeframe
Report page 15Response page 32

recommendation · PROTEM-R4

Improve the financial management practices beginning with immediately balancing the budget and bolstering internal control processes. Complete all annual financial reports on time. Based on Finding: F-1, F-3, F-4, F-5, F-8 Implementation: July 1, 2027 Financial Impact: Moderate

County: Will be implementedAudit: Addressed

Response says

Plans budget and control improvements, with qualified efforts toward annual reporting by July 1, 2027.

Audit analysis

Pages 32–33 describe an anticipated September budget action and efforts dependent on reporting/audit work. These are qualified plans, not an adopted balanced budget or a guarantee that all reports will be current.

Extracted commitments

Pursue the described budget, internal-control and annual-report improvements.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified. · Conditional timing
Report page 15Response page 32

recommendation · PROTEM-R5

Review, compare, and implement a newer software application including Cloud solutions to update the current billing system. Based on Finding: F-5 Implementation: Immediately Financial Impact: Moderate/High

County: Will not be implementedAudit: Addressed

Response says

Will not replace the underlying software as proposed; plans existing-system upgrades instead.

Audit analysis

The response explains cost, licensing and existing-system considerations and describes two alternative phases. Refusal is not reclassified as completed replacement.

Extracted commitments

Pursue the alternative billing-system upgrade.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
Estimated July 2027 phase; not a guaranteed completion day. · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
Estimated November 2027 phase; not a guaranteed completion day. · Conditional timing
Report page 15Response page 33

recommendation · PROTEM-R6

Initiate a comprehensive onboarding and offboarding program to include appropriate training, transfer of knowledge, and clarity for job responsibilities. Take all necessary steps to improve the culture through transparency, training and collaboration. Based on Finding: F-6 Implementation: Immediately Financial Impact: Low

County: Will be implementedAudit: Addressed

Response says

Will prepare onboarding/offboarding and organizational-culture programs.

Audit analysis

The response names November 1, 2026 and January 1, 2027 program-readiness targets, not implementation immediately as the jury proposed.

Extracted commitments

Prepare the described comprehensive onboarding and offboarding program.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
2026-11-01 · Exact date

Prepare a detailed organizational-culture program for implementation.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
2027-01-01 · Exact date
Report page 15Response page 34

recommendation · PROTEM-R7

Create a central policy location on SharePoint or similar program, organized by department, that is accessible and easy to locate. Update all policies and procedures to reflect current city, state, and federal guidelines and review and revise annually as needed. Enforce policies through staff training and accountability mechanisms. Based on Finding: F-6 and F-7 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Partially addressed

Response says

Claims SharePoint exists and promises policy updates and later training.

Audit analysis

The source image confirms October 1, 2026, not the OCR’s 2028, for policy updates; the heading gives November 1, 2027 for training. HR and Finance updates are described, but annual citywide review/enforcement scope is not fully specified.

Extracted commitments

Update the described HR and Finance policies.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
2026-10-01 · Exact date

Deliver the training described by the response heading.

Responsible party
Banning Mayor Pro Tem Cindy Barrington
Timing
2027-11-01 · Exact date
Report page 16Response page 34

recommendation · PROTEM-R8

Promptly establish an impartial, thorough, and efficient investigation process for all harassment complaints utilizing qualified and trained personnel to ensure due process for every employee including elected officials. Based on Finding: F-6 and F-7 Implementation: Immediately Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims an impartial complaint-investigation process is implemented.

Audit analysis

The response cites qualified personnel and procedures. No independent review of individual harassment investigations is implied.

Report page 16Response page 35

recommendation · PROTEM-R9

Draft and implement a strategic plan to address all issues related to financial and personnel matters existing within the City of Banning. Based on Finding: F-4 and F-8 Implementation: Immediately Financial Impact: Low/Moderate.

County: ImplementedAudit: Addressed

Response says

Claims a strategic plan is implemented.

Audit analysis

The answer relies on the planning materials and history discussed under F8; a plan is not proof every financial or personnel action has been completed.

Report page 16Response page 35

finding · WALLACE-F1

The Banning Electric Utility (BEU) went from a $31 million surplus in 2018, to a $9 million deficit in 2022.

Audit: Addressed

Response says

Partly disagrees; distinguishes fund balance, cash, adjustments and reconciliations.

Audit analysis

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Scoring confidence: high

Report page 14Response page 22
Discuss finding and response

finding · WALLACE-F2

Multiple sources have stated that the City of Banning may have transferred revenue from the BEU to the General Fund. These transfers would be in violation of Propositions 26 and 218 after Measure P was rejected by the voters in November 2018.

Audit: Addressed

Response says

Partly disagrees; denies recent unlawful transfers and does not resolve every older year.

Audit analysis

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Scoring confidence: high

Report page 14Response page 23
Discuss finding and response

finding · WALLACE-F3

The Cost Allocation Plan utilized from 2018 to present contains serious errors and lack internal controls.

Audit: Addressed

Response says

Partly disagrees; distinguishes current allocation work from historical weaknesses.

Audit analysis

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · WALLACE-F4

Per Standard & Poor’s Global Rating Report, the electric system revenue bond rating has been downgraded from A- in 2007 to B (junk status) in 2026.

Audit: Addressed

Response says

Agrees, with dated rating history and fiscal context.

Audit analysis

Pages 25–26 cite S&P downgrade dates, late audited statements and financial pressures. These are specific traceable explanations, not an independent audit or verified forecast of recovery.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated S&P actions and identified reporting and financial issues support the explanation; agreement does not require a disagreement rationale.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · WALLACE-F5

The City of Banning is currently experiencing a monumental billing crisis due to an antiquated billing system and failed software rollout.

Audit: Addressed

Response says

Partly disagrees; accepts the November 2024–April 2026 billing crisis but denies it continues and disputes the proposed fiscal-transfer connection.

Audit analysis

Pages 26–27 attribute the crisis to software purchase and rollout, claim current monthly billing and distinguish catch-up bills from double charging. July 14 payment-plan action is cited. These are agency explanations, not independently verified billing outcomes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

The disputed period and causal inference are explicit, with dated payment-plan and software-transition details.

Scoring confidence: high

Report page 14Response page 26
Discuss finding and response

finding · WALLACE-F6

The City of Banning has experienced a substantial turnover of essential personnel.

Audit: Addressed

Response says

Agrees, with recruitment, budget and strategic-plan context.

Audit analysis

Pages 27–28 acknowledge turnover and describe recruitment, planned initiatives and fiscal constraints. Named strategic-plan measures are traceable explanations, not independently verified staff retention results.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Agreement is explicit; the response names strategic planning and budget/recruitment mechanisms behind its explanation.

Scoring confidence: high

Report page 14Response page 27
Discuss finding and response

finding · WALLACE-F7

Human resources policies and procedures are outdated and not enforced, leaving the City vulnerable to litigation.

Audit: Addressed

Response says

Partly disagrees; accepts some policy-update needs and disputes nonenforcement.

Audit analysis

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Scoring confidence: high

Report page 14Response page 28
Discuss finding and response

finding · WALLACE-F8

The City of Banning is currently operating without a strategic plan.

Audit: Addressed

Response says

Disagrees that the City operates without a strategic plan.

Audit analysis

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Scoring confidence: high

Report page 14Response page 30
Discuss finding and response

recommendation · WALLACE-R1

Conduct a transparent audit of all BEU finances and ledger activity to determine if any fund transfers violated the terms of Propositions 26 and 218 after Measure P was defeated. Based on Findings: F-1, F-2, F-4 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Addressed

Response says

Will review the relevant accounting and ledger activity by January 1, 2027.

Audit analysis

The respondent describes a future review of the disputed transfers rather than an already completed audit or legal conclusion.

Extracted commitments

Complete the described review of BEU financial and ledger activity.

Responsible party
Banning Council Member Colleen Wallace
Timing
2027-01-01 · Exact date
Report page 15Response page 31

recommendation · WALLACE-R2

Distinctly separate the BEU financial data from other City departments by reviewing best practices of other cities that operate their own municipal electric utilities. Based on Findings: F-1, F-2, F-4 Implementation: December 31, 2026 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims financial separation already exists; promises a peer review before the FY 2025–2026 ACFR.

Audit analysis

Separate accounting is claimed as existing. The additional event-bounded comparison is future work, not proof that all requested best practices have been evaluated.

Extracted commitments

Review peer municipal-electric accounting practices before the stated annual financial report.

Responsible party
Banning Council Member Colleen Wallace
Timing
Before publication of the FY 2025–2026 ACFR; no calendar date supplied. · Bounded timeframe
Report page 15Response page 31

recommendation · WALLACE-R3

Manage Cost Allocation Plans to ensure current, accurate, and transparent documentation. Based on Finding: F-3 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims June 2026 implementation and promises annual allocation-plan review.

Audit analysis

The response claims the Finance Director implemented the recommendation in June 2026 and will review allocations annually during the budget process. It supplies no July 2027 review deadline.

Extracted commitments

Review allocation-plan appropriateness annually during the budget process.

Responsible party
Banning Council Member Colleen Wallace
Timing
Annually as part of the annual budget process; no calendar completion date supplied. · Bounded timeframe
Report page 15Response page 32

recommendation · WALLACE-R4

Improve the financial management practices beginning with immediately balancing the budget and bolstering internal control processes. Complete all annual financial reports on time. Based on Finding: F-1, F-3, F-4, F-5, F-8 Implementation: July 1, 2027 Financial Impact: Moderate

County: Will be implementedAudit: Addressed

Response says

Plans budget and control improvements, with qualified efforts toward annual reporting by July 1, 2027.

Audit analysis

Pages 32–33 describe an anticipated September budget action and efforts dependent on reporting/audit work. These are qualified plans, not an adopted balanced budget or a guarantee that all reports will be current.

Extracted commitments

Pursue the described budget, internal-control and annual-report improvements.

Responsible party
Banning Council Member Colleen Wallace
Timing
Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified. · Conditional timing
Report page 15Response page 32

recommendation · WALLACE-R5

Review, compare, and implement a newer software application including Cloud solutions to update the current billing system. Based on Finding: F-5 Implementation: Immediately Financial Impact: Moderate/High

County: Will not be implementedAudit: Addressed

Response says

Will not replace the underlying software as proposed; plans existing-system upgrades instead.

Audit analysis

The response explains cost, licensing and existing-system considerations and describes two alternative phases. Refusal is not reclassified as completed replacement.

Extracted commitments

Pursue the alternative billing-system upgrade.

Responsible party
Banning Council Member Colleen Wallace
Timing
Estimated July 2027 phase; not a guaranteed completion day. · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Responsible party
Banning Council Member Colleen Wallace
Timing
Estimated November 2027 phase; not a guaranteed completion day. · Conditional timing
Report page 15Response page 33

recommendation · WALLACE-R6

Initiate a comprehensive onboarding and offboarding program to include appropriate training, transfer of knowledge, and clarity for job responsibilities. Take all necessary steps to improve the culture through transparency, training and collaboration. Based on Finding: F-6 Implementation: Immediately Financial Impact: Low

County: Will be implementedAudit: Addressed

Response says

Will prepare onboarding/offboarding and organizational-culture programs.

Audit analysis

The response names November 1, 2026 and January 1, 2027 program-readiness targets, not implementation immediately as the jury proposed.

Extracted commitments

Prepare the described comprehensive onboarding and offboarding program.

Responsible party
Banning Council Member Colleen Wallace
Timing
2026-11-01 · Exact date

Prepare a detailed organizational-culture program for implementation.

Responsible party
Banning Council Member Colleen Wallace
Timing
2027-01-01 · Exact date
Report page 15Response page 34

recommendation · WALLACE-R7

Create a central policy location on SharePoint or similar program, organized by department, that is accessible and easy to locate. Update all policies and procedures to reflect current city, state, and federal guidelines and review and revise annually as needed. Enforce policies through staff training and accountability mechanisms. Based on Finding: F-6 and F-7 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Partially addressed

Response says

Claims SharePoint exists and promises policy updates and later training.

Audit analysis

The source image confirms October 1, 2026, not the OCR’s 2028, for policy updates; the heading gives November 1, 2027 for training. HR and Finance updates are described, but annual citywide review/enforcement scope is not fully specified.

Extracted commitments

Update the described HR and Finance policies.

Responsible party
Banning Council Member Colleen Wallace
Timing
2026-10-01 · Exact date

Deliver the training described by the response heading.

Responsible party
Banning Council Member Colleen Wallace
Timing
2027-11-01 · Exact date
Report page 16Response page 34

recommendation · WALLACE-R8

Promptly establish an impartial, thorough, and efficient investigation process for all harassment complaints utilizing qualified and trained personnel to ensure due process for every employee including elected officials. Based on Finding: F-6 and F-7 Implementation: Immediately Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims an impartial complaint-investigation process is implemented.

Audit analysis

The response cites qualified personnel and procedures. No independent review of individual harassment investigations is implied.

Report page 16Response page 35

recommendation · WALLACE-R9

Draft and implement a strategic plan to address all issues related to financial and personnel matters existing within the City of Banning. Based on Finding: F-4 and F-8 Implementation: Immediately Financial Impact: Low/Moderate.

County: ImplementedAudit: Addressed

Response says

Claims a strategic plan is implemented.

Audit analysis

The answer relies on the planning materials and history discussed under F8; a plan is not proof every financial or personnel action has been completed.

Report page 16Response page 35

finding · MILLER-F1

The Banning Electric Utility (BEU) went from a $31 million surplus in 2018, to a $9 million deficit in 2022.

Audit: Addressed

Response says

Partly disagrees; distinguishes fund balance, cash, adjustments and reconciliations.

Audit analysis

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Scoring confidence: high

Report page 14Response page 22
Discuss finding and response

finding · MILLER-F2

Multiple sources have stated that the City of Banning may have transferred revenue from the BEU to the General Fund. These transfers would be in violation of Propositions 26 and 218 after Measure P was rejected by the voters in November 2018.

Audit: Addressed

Response says

Partly disagrees; denies recent unlawful transfers and does not resolve every older year.

Audit analysis

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Scoring confidence: high

Report page 14Response page 23
Discuss finding and response

finding · MILLER-F3

The Cost Allocation Plan utilized from 2018 to present contains serious errors and lack internal controls.

Audit: Addressed

Response says

Partly disagrees; distinguishes current allocation work from historical weaknesses.

Audit analysis

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MILLER-F4

Per Standard & Poor’s Global Rating Report, the electric system revenue bond rating has been downgraded from A- in 2007 to B (junk status) in 2026.

Audit: Addressed

Response says

Agrees, with dated rating history and fiscal context.

Audit analysis

Pages 25–26 cite S&P downgrade dates, late audited statements and financial pressures. These are specific traceable explanations, not an independent audit or verified forecast of recovery.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated S&P actions and identified reporting and financial issues support the explanation; agreement does not require a disagreement rationale.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MILLER-F5

The City of Banning is currently experiencing a monumental billing crisis due to an antiquated billing system and failed software rollout.

Audit: Addressed

Response says

Partly disagrees; accepts the November 2024–April 2026 billing crisis but denies it continues and disputes the proposed fiscal-transfer connection.

Audit analysis

Pages 26–27 attribute the crisis to software purchase and rollout, claim current monthly billing and distinguish catch-up bills from double charging. July 14 payment-plan action is cited. These are agency explanations, not independently verified billing outcomes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

The disputed period and causal inference are explicit, with dated payment-plan and software-transition details.

Scoring confidence: high

Report page 14Response page 26
Discuss finding and response

finding · MILLER-F6

The City of Banning has experienced a substantial turnover of essential personnel.

Audit: Addressed

Response says

Agrees, with recruitment, budget and strategic-plan context.

Audit analysis

Pages 27–28 acknowledge turnover and describe recruitment, planned initiatives and fiscal constraints. Named strategic-plan measures are traceable explanations, not independently verified staff retention results.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Agreement is explicit; the response names strategic planning and budget/recruitment mechanisms behind its explanation.

Scoring confidence: high

Report page 14Response page 27
Discuss finding and response

finding · MILLER-F7

Human resources policies and procedures are outdated and not enforced, leaving the City vulnerable to litigation.

Audit: Addressed

Response says

Partly disagrees; accepts some policy-update needs and disputes nonenforcement.

Audit analysis

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Scoring confidence: high

Report page 14Response page 28
Discuss finding and response

finding · MILLER-F8

The City of Banning is currently operating without a strategic plan.

Audit: Addressed

Response says

Disagrees that the City operates without a strategic plan.

Audit analysis

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Scoring confidence: high

Report page 14Response page 30
Discuss finding and response

recommendation · MILLER-R1

Conduct a transparent audit of all BEU finances and ledger activity to determine if any fund transfers violated the terms of Propositions 26 and 218 after Measure P was defeated. Based on Findings: F-1, F-2, F-4 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Addressed

Response says

Will review the relevant accounting and ledger activity by January 1, 2027.

Audit analysis

The respondent describes a future review of the disputed transfers rather than an already completed audit or legal conclusion.

Extracted commitments

Complete the described review of BEU financial and ledger activity.

Responsible party
Banning Council Member Leroy Miller
Timing
2027-01-01 · Exact date
Report page 15Response page 31

recommendation · MILLER-R2

Distinctly separate the BEU financial data from other City departments by reviewing best practices of other cities that operate their own municipal electric utilities. Based on Findings: F-1, F-2, F-4 Implementation: December 31, 2026 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims financial separation already exists; promises a peer review before the FY 2025–2026 ACFR.

Audit analysis

Separate accounting is claimed as existing. The additional event-bounded comparison is future work, not proof that all requested best practices have been evaluated.

Extracted commitments

Review peer municipal-electric accounting practices before the stated annual financial report.

Responsible party
Banning Council Member Leroy Miller
Timing
Before publication of the FY 2025–2026 ACFR; no calendar date supplied. · Bounded timeframe
Report page 15Response page 31

recommendation · MILLER-R3

Manage Cost Allocation Plans to ensure current, accurate, and transparent documentation. Based on Finding: F-3 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims June 2026 implementation and promises annual allocation-plan review.

Audit analysis

The response claims the Finance Director implemented the recommendation in June 2026 and will review allocations annually during the budget process. It supplies no July 2027 review deadline.

Extracted commitments

Review allocation-plan appropriateness annually during the budget process.

Responsible party
Banning Council Member Leroy Miller
Timing
Annually as part of the annual budget process; no calendar completion date supplied. · Bounded timeframe
Report page 15Response page 32

recommendation · MILLER-R4

Improve the financial management practices beginning with immediately balancing the budget and bolstering internal control processes. Complete all annual financial reports on time. Based on Finding: F-1, F-3, F-4, F-5, F-8 Implementation: July 1, 2027 Financial Impact: Moderate

County: Will be implementedAudit: Addressed

Response says

Plans budget and control improvements, with qualified efforts toward annual reporting by July 1, 2027.

Audit analysis

Pages 32–33 describe an anticipated September budget action and efforts dependent on reporting/audit work. These are qualified plans, not an adopted balanced budget or a guarantee that all reports will be current.

Extracted commitments

Pursue the described budget, internal-control and annual-report improvements.

Responsible party
Banning Council Member Leroy Miller
Timing
Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified. · Conditional timing
Report page 15Response page 32

recommendation · MILLER-R5

Review, compare, and implement a newer software application including Cloud solutions to update the current billing system. Based on Finding: F-5 Implementation: Immediately Financial Impact: Moderate/High

County: Will not be implementedAudit: Addressed

Response says

Will not replace the underlying software as proposed; plans existing-system upgrades instead.

Audit analysis

The response explains cost, licensing and existing-system considerations and describes two alternative phases. Refusal is not reclassified as completed replacement.

Extracted commitments

Pursue the alternative billing-system upgrade.

Responsible party
Banning Council Member Leroy Miller
Timing
Estimated July 2027 phase; not a guaranteed completion day. · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Responsible party
Banning Council Member Leroy Miller
Timing
Estimated November 2027 phase; not a guaranteed completion day. · Conditional timing
Report page 15Response page 33

recommendation · MILLER-R6

Initiate a comprehensive onboarding and offboarding program to include appropriate training, transfer of knowledge, and clarity for job responsibilities. Take all necessary steps to improve the culture through transparency, training and collaboration. Based on Finding: F-6 Implementation: Immediately Financial Impact: Low

County: Will be implementedAudit: Addressed

Response says

Will prepare onboarding/offboarding and organizational-culture programs.

Audit analysis

The response names November 1, 2026 and January 1, 2027 program-readiness targets, not implementation immediately as the jury proposed.

Extracted commitments

Prepare the described comprehensive onboarding and offboarding program.

Responsible party
Banning Council Member Leroy Miller
Timing
2026-11-01 · Exact date

Prepare a detailed organizational-culture program for implementation.

Responsible party
Banning Council Member Leroy Miller
Timing
2027-01-01 · Exact date
Report page 15Response page 34

recommendation · MILLER-R7

Create a central policy location on SharePoint or similar program, organized by department, that is accessible and easy to locate. Update all policies and procedures to reflect current city, state, and federal guidelines and review and revise annually as needed. Enforce policies through staff training and accountability mechanisms. Based on Finding: F-6 and F-7 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Partially addressed

Response says

Claims SharePoint exists and promises policy updates and later training.

Audit analysis

The source image confirms October 1, 2026, not the OCR’s 2028, for policy updates; the heading gives November 1, 2027 for training. HR and Finance updates are described, but annual citywide review/enforcement scope is not fully specified.

Extracted commitments

Update the described HR and Finance policies.

Responsible party
Banning Council Member Leroy Miller
Timing
2026-10-01 · Exact date

Deliver the training described by the response heading.

Responsible party
Banning Council Member Leroy Miller
Timing
2027-11-01 · Exact date
Report page 16Response page 34

recommendation · MILLER-R8

Promptly establish an impartial, thorough, and efficient investigation process for all harassment complaints utilizing qualified and trained personnel to ensure due process for every employee including elected officials. Based on Finding: F-6 and F-7 Implementation: Immediately Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims an impartial complaint-investigation process is implemented.

Audit analysis

The response cites qualified personnel and procedures. No independent review of individual harassment investigations is implied.

Report page 16Response page 35

recommendation · MILLER-R9

Draft and implement a strategic plan to address all issues related to financial and personnel matters existing within the City of Banning. Based on Finding: F-4 and F-8 Implementation: Immediately Financial Impact: Low/Moderate.

County: ImplementedAudit: Addressed

Response says

Claims a strategic plan is implemented.

Audit analysis

The answer relies on the planning materials and history discussed under F8; a plan is not proof every financial or personnel action has been completed.

Report page 16Response page 35

finding · MANAGER-F1

The Banning Electric Utility (BEU) went from a $31 million surplus in 2018, to a $9 million deficit in 2022.

Audit: Addressed

Response says

Partly disagrees; distinguishes fund balance, cash, adjustments and reconciliations.

Audit analysis

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 22–23 discuss the reported years and types of financial measures. These distinctions identify the disputed comparison but are not an independent financial audit.

Scoring confidence: high

Report page 14Response page 22
Discuss finding and response

finding · MANAGER-F2

Multiple sources have stated that the City of Banning may have transferred revenue from the BEU to the General Fund. These transfers would be in violation of Propositions 26 and 218 after Measure P was rejected by the voters in November 2018.

Audit: Addressed

Response says

Partly disagrees; denies recent unlawful transfers and does not resolve every older year.

Audit analysis

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Pages 23–24 distinguish current/recent practices from historical matters requiring further review. This limits coverage of the full period rather than proving legality.

Scoring confidence: high

Report page 14Response page 23
Discuss finding and response

finding · MANAGER-F3

The Cost Allocation Plan utilized from 2018 to present contains serious errors and lack internal controls.

Audit: Addressed

Response says

Partly disagrees; distinguishes current allocation work from historical weaknesses.

Audit analysis

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 24–25 discuss allocation plans and controls over time. Clear temporal disagreement is not treated as independent verification of all historical costs.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MANAGER-F4

Per Standard & Poor’s Global Rating Report, the electric system revenue bond rating has been downgraded from A- in 2007 to B (junk status) in 2026.

Audit: Addressed

Response says

Agrees, with dated rating history and fiscal context.

Audit analysis

Pages 25–26 cite S&P downgrade dates, late audited statements and financial pressures. These are specific traceable explanations, not an independent audit or verified forecast of recovery.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Dated S&P actions and identified reporting and financial issues support the explanation; agreement does not require a disagreement rationale.

Scoring confidence: high

Report page 14Response page 25
Discuss finding and response

finding · MANAGER-F5

The City of Banning is currently experiencing a monumental billing crisis due to an antiquated billing system and failed software rollout.

Audit: Addressed

Response says

Partly disagrees; accepts the November 2024–April 2026 billing crisis but denies it continues and disputes the proposed fiscal-transfer connection.

Audit analysis

Pages 26–27 attribute the crisis to software purchase and rollout, claim current monthly billing and distinguish catch-up bills from double charging. July 14 payment-plan action is cited. These are agency explanations, not independently verified billing outcomes.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

The disputed period and causal inference are explicit, with dated payment-plan and software-transition details.

Scoring confidence: high

Report page 14Response page 26
Discuss finding and response

finding · MANAGER-F6

The City of Banning has experienced a substantial turnover of essential personnel.

Audit: Addressed

Response says

Agrees, with recruitment, budget and strategic-plan context.

Audit analysis

Pages 27–28 acknowledge turnover and describe recruitment, planned initiatives and fiscal constraints. Named strategic-plan measures are traceable explanations, not independently verified staff retention results.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Agreement is explicit; the response names strategic planning and budget/recruitment mechanisms behind its explanation.

Scoring confidence: high

Report page 14Response page 27
Discuss finding and response

finding · MANAGER-F7

Human resources policies and procedures are outdated and not enforced, leaving the City vulnerable to litigation.

Audit: Addressed

Response says

Partly disagrees; accepts some policy-update needs and disputes nonenforcement.

Audit analysis

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 26–28 distinguish old policies from alleged enforcement failures and cite policy, legal and memorandum-of-understanding considerations.

Scoring confidence: high

Report page 14Response page 28
Discuss finding and response

finding · MANAGER-F8

The City of Banning is currently operating without a strategic plan.

Audit: Addressed

Response says

Disagrees that the City operates without a strategic plan.

Audit analysis

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Pages 28–30 cite dated planning activity, prior plans and Council materials. These are traceable explanations, not independent evidence that every stated goal is implemented.

Scoring confidence: high

Report page 14Response page 30
Discuss finding and response

recommendation · MANAGER-R1

Conduct a transparent audit of all BEU finances and ledger activity to determine if any fund transfers violated the terms of Propositions 26 and 218 after Measure P was defeated. Based on Findings: F-1, F-2, F-4 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Addressed

Response says

Will review the relevant accounting and ledger activity by January 1, 2027.

Audit analysis

The respondent describes a future review of the disputed transfers rather than an already completed audit or legal conclusion.

Extracted commitments

Complete the described review of BEU financial and ledger activity.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
2027-01-01 · Exact date
Report page 15Response page 31

recommendation · MANAGER-R2

Distinctly separate the BEU financial data from other City departments by reviewing best practices of other cities that operate their own municipal electric utilities. Based on Findings: F-1, F-2, F-4 Implementation: December 31, 2026 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims financial separation already exists; promises a peer review before the FY 2025–2026 ACFR.

Audit analysis

Separate accounting is claimed as existing. The additional event-bounded comparison is future work, not proof that all requested best practices have been evaluated.

Extracted commitments

Review peer municipal-electric accounting practices before the stated annual financial report.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
Before publication of the FY 2025–2026 ACFR; no calendar date supplied. · Bounded timeframe
Report page 15Response page 31

recommendation · MANAGER-R3

Manage Cost Allocation Plans to ensure current, accurate, and transparent documentation. Based on Finding: F-3 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims June 2026 implementation and promises annual allocation-plan review.

Audit analysis

The response claims the Finance Director implemented the recommendation in June 2026 and will review allocations annually during the budget process. It supplies no July 2027 review deadline.

Extracted commitments

Review allocation-plan appropriateness annually during the budget process.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
Annually as part of the annual budget process; no calendar completion date supplied. · Bounded timeframe
Report page 15Response page 32

recommendation · MANAGER-R4

Improve the financial management practices beginning with immediately balancing the budget and bolstering internal control processes. Complete all annual financial reports on time. Based on Finding: F-1, F-3, F-4, F-5, F-8 Implementation: July 1, 2027 Financial Impact: Moderate

County: Will be implementedAudit: Addressed

Response says

Plans budget and control improvements, with qualified efforts toward annual reporting by July 1, 2027.

Audit analysis

Pages 32–33 describe an anticipated September budget action and efforts dependent on reporting/audit work. These are qualified plans, not an adopted balanced budget or a guarantee that all reports will be current.

Extracted commitments

Pursue the described budget, internal-control and annual-report improvements.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
Financial-report work targeted toward July 1, 2027, subject to the qualifications and external reporting dependencies in the response; September 2026 budget action is anticipated, not independently verified. · Conditional timing
Report page 15Response page 32

recommendation · MANAGER-R5

Review, compare, and implement a newer software application including Cloud solutions to update the current billing system. Based on Finding: F-5 Implementation: Immediately Financial Impact: Moderate/High

County: Will not be implementedAudit: Addressed

Response says

Will not replace the underlying software as proposed; plans existing-system upgrades instead.

Audit analysis

The response explains cost, licensing and existing-system considerations and describes two alternative phases. Refusal is not reclassified as completed replacement.

Extracted commitments

Pursue the alternative billing-system upgrade.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
Estimated July 2027 phase; not a guaranteed completion day. · Conditional timing

Review utility-billing business processes and consider a new system or cloud option based on the results.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
Estimated November 2027 phase; not a guaranteed completion day. · Conditional timing
Report page 15Response page 33

recommendation · MANAGER-R6

Initiate a comprehensive onboarding and offboarding program to include appropriate training, transfer of knowledge, and clarity for job responsibilities. Take all necessary steps to improve the culture through transparency, training and collaboration. Based on Finding: F-6 Implementation: Immediately Financial Impact: Low

County: Will be implementedAudit: Addressed

Response says

Will prepare onboarding/offboarding and organizational-culture programs.

Audit analysis

The response names November 1, 2026 and January 1, 2027 program-readiness targets, not implementation immediately as the jury proposed.

Extracted commitments

Prepare the described comprehensive onboarding and offboarding program.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
2026-11-01 · Exact date

Prepare a detailed organizational-culture program for implementation.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
2027-01-01 · Exact date
Report page 15Response page 34

recommendation · MANAGER-R7

Create a central policy location on SharePoint or similar program, organized by department, that is accessible and easy to locate. Update all policies and procedures to reflect current city, state, and federal guidelines and review and revise annually as needed. Enforce policies through staff training and accountability mechanisms. Based on Finding: F-6 and F-7 Implementation: January 1, 2027 Financial Impact: Low/Moderate

County: Will be implementedAudit: Partially addressed

Response says

Claims SharePoint exists and promises policy updates and later training.

Audit analysis

The source image confirms October 1, 2026, not the OCR’s 2028, for policy updates; the heading gives November 1, 2027 for training. HR and Finance updates are described, but annual citywide review/enforcement scope is not fully specified.

Extracted commitments

Update the described HR and Finance policies.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
2026-10-01 · Exact date

Deliver the training described by the response heading.

Responsible party
Banning City Manager Elizabeth M. Gibbs
Timing
2027-11-01 · Exact date
Report page 16Response page 34

recommendation · MANAGER-R8

Promptly establish an impartial, thorough, and efficient investigation process for all harassment complaints utilizing qualified and trained personnel to ensure due process for every employee including elected officials. Based on Finding: F-6 and F-7 Implementation: Immediately Financial Impact: Low/Moderate

County: ImplementedAudit: Addressed

Response says

Claims an impartial complaint-investigation process is implemented.

Audit analysis

The response cites qualified personnel and procedures. No independent review of individual harassment investigations is implied.

Report page 16Response page 35

recommendation · MANAGER-R9

Draft and implement a strategic plan to address all issues related to financial and personnel matters existing within the City of Banning. Based on Finding: F-4 and F-8 Implementation: Immediately Financial Impact: Low/Moderate.

County: ImplementedAudit: Addressed

Response says

Claims a strategic plan is implemented.

Audit analysis

The answer relies on the planning materials and history discussed under F8; a plan is not proof every financial or personnel action has been completed.

Report page 16Response page 35