III. Chapter Directory

I. Correspondence Header

Dear UCLA Compliance Office:

I respectfully disagree with your April 17, 2026 determination in CMP373 and request that this matter be referred immediately to an outside agency for independent review. The grounds for this request are set forth below.

UCLA Compliance’s April 17, 2026 letter states on its face that the determination was based on “your complaints and documentation we received from UCLA PD.” UCLA Compliance did not interview the complainant, did not request Harold’s own documentary record, and did not independently gather evidence. UCLA Compliance’s conclusion rests entirely on a record curated and delivered by UCLA PD — the agency whose officers are the subjects of the complaints. A Compliance determination that relies on evidence hand-selected by the accused agency is not an independent review; it is a procedural rubber stamp.

Stated more directly: the office charged with ensuring UC’s compliance with the law has, in this matter, conducted itself in a manner that bears the hallmarks of collusion with the investigated agency, extrinsic fraud as to the complainant, and — given the underlying California Labor Code § 132(a) crime report UCLA PD has now ignored for fifty-seven days — obstruction of justice. UCLA’s own Compliance Office is, at this moment, out of compliance.

Specific UC and California authorities violated by the April 17, 2026 determination:

Three structural failures appear on the face of the April 17, 2026 letter:

A. Procedural invalidity. UCLA Compliance never interviewed the complainant. There was no telephone contact, no email correspondence, no in-person meeting, and no written questionnaire issued to Harold. A determination issued without any contact with the complainant fails UC Whistleblower Policy 1100171 § II.B.6, which provides that “internal communications regarding allegations of improper governmental activities should normally be in writing” and that supervisors should “document oral reports by written transcription.” UCLA Compliance produced a determination without ever creating, requesting, or receiving any oral or written record from the person who filed the complaints.

B. Cognitive dissonance and the halo effect in PD command-staff self-curation. The April 17, 2026 letter expressly identifies UCLA PD as the source of the documentation on which the determination relied. UCLA PD — the agency containing Captain Jeff Chobanian (Badge #307) and the Chief of Police whose conduct is the subject of the underlying POST complaints — selected, organized, and delivered the evidentiary record on which UCLA Compliance then ruled. This is the exact structural conflict the ECAS February 2023 audit identified as systemwide policy failure and directed UC to prohibit. The April 17, 2026 determination demonstrates that, three years after the ECAS finding, the conflict the audit warned of is operative at UCLA.

C. UC’s own 1996 institutional precedent contradicts the April 17, 2026 determination. In the 1990s, UCLA Police Officer Charles Harold conducted a criminal investigation and exposed institutional corruption at UCLA PD. UC investigated, substantiated the report, and terminated the UCLA Chief of Police and members of command staff. Those events are documented in UCLA’s own Luskin Center for History and Policy publication, The History of Racism and the Quest for Racial Justice at UCLA (March 2022, pp. 35–36, footnotes 147–164). The officer who conducted that investigation is the same complainant whose successor pattern is now before UCLA Compliance. UC’s 1996 finding stands as UC’s own institutional admission that the conduct Harold reported — then and now — was wrongful. UCLA Compliance has issued a “no policy violation” finding on substantively similar facts from the same complainant, without interviewing him, on a record curated by the agency he reported.

Remedy requested. Pursuant to UC Whistleblower Policy 1100171 § II.C.2, this matter is hereby referred for independent review to an outside agency. The undersigned requests that UCLA Compliance refer this matter to one or more of the following: (i) the California State Auditor (Whistleblower Hotline, (800) 952-5665); (ii) the California Attorney General; (iii) the California Commission on Peace Officer Standards and Training (POST), in connection with already-pending complaints PUBLIC-26-000212, -000213, and -000214; (iv) the UC Systemwide Locally Designated Official at the Office of the President; or (v) a UC sister-campus compliance office free of conflict. A response identifying the agency or agencies to which this matter has been referred is requested within thirty (30) days of receipt of this letter.

Preservation notice. All UCLA PD, UCLA Compliance, UCOP, UC General Counsel, and Regents of the University of California records relating to CMP373, the February 19, 2026 California Labor Code § 132(a) crime report, the three POST complaints, and the April 17, 2026 determination are subject to litigation hold as of the date of this letter. Spoliation of any such record will be addressed under California Evidence Code § 413 and applicable common law.

Very respectfully,

Charles A. Harold Jr.
UCLA Police Department (Retired?), Badge #341
Founder and First President, FUPOA

II. Preliminary Notice Regarding Premium Non-Payment, Direct Payment Offer, and Coverage Certificate Discrepancy

IV. Foundational Requirement for All Responses

V. Evidence Index with Source Filenames

The following table identifies each exhibit referenced in this document, the question(s) it supports, and the source filename for locating the document in the evidentiary record.

VI. Statute, Rule, and Policy Appendix

The following statutes, regulations, and UC policies are cited or implicated in this document.

Federal Statutes

[F-1] 42 U.S.C. § 1395ss(q)(1) — Prohibition on cancellation of Medigap coverage based on geographic location (Q12, Q34)

[F-2] 42 U.S.C. § 1395ss(q)(2)–(3) — Requirement to offer individual Medigap upon group termination; guaranteed issue rights (Q34, Q40)

[F-3] 18 U.S.C. § 926C (LEOSA) — Concealed carry for retired peace officers (Q6, Q7)

[F-4] Fair Labor Standards Act (FLSA) — Basis for Case No. 2:96-cv-00396-WDK-AJW (Q33)

[F-5] 31 U.S.C. §§ 3729–3733 — False Claims Act (Questions A–K, Financial Context)

[F-6] 42 U.S.C. § 1320a-7b(b) — Anti-Kickback Statute; prohibition on kickbacks in connection with Medicare beneficiary referrals (Question G, Financial Context) | DOJ Press Release

[F-7] 15 U.S.C. § 18 (Clayton Act) / DOJ Antitrust Division — United States v. Aon plc, Case No. 1:21-cv-01633 (D.D.C.) (Question F, Financial Context) | DOJ Press Release

[F-8] 42 U.S.C. § 6101 et seq. — Age Discrimination Act of 1975; prohibits age discrimination in programs receiving federal financial assistance (Questions D, I)

[F-9] 42 U.S.C. § 12101 et seq. — Americans with Disabilities Act (ADA); prohibition on disability discrimination (Question H)

[F-10] 42 U.S.C. § 18116 — Affordable Care Act, Section 1557; prohibition on age and disability discrimination in federally funded health programs (Questions I, J)

[F-11] 45 C.F.R. Part 92 — HHS implementing regulations for ACA Section 1557 (Question J)

California Constitution

[CA-1] Article IX, Section 9 — UC as a “public trust”; Regents’ constitutional autonomy (Audit Request Box)

[CA-2] Article XVI, Section 17(b) — Fiduciary duty of loyalty to retirement plan participants takes precedence over any other duty (Questions A–K)

California Statutes

[CS-1] Gov. Code § 8546.7 — State Auditor examination of public fund contracts (Cover, Audit Box, Q39, Closing)

[CS-2] Gov. Code § 8547.2(c)(2) — Whistleblower Protection Act (Audit Box)

[CS-3] Gov. Code § 8547.11 — Whistleblower provisions applied to UC (Audit Box)

[CS-4] Gov. Code § 3306.5 — POBR personnel records access (Q30)

[CS-5] Labor Code § 1102.5 — Whistleblower retaliation protection (Q10)

[CS-6] Labor Code § 5803 — WCAB continuing jurisdiction (Q28)

[CS-7] Labor Code § 132a — Discrimination against injured workers (Cover Page)

[CS-8] Penal Code §§ 25455, 25460, 25465 — Concealed carry for retired officers (Q7)

[CS-9] Penal Code § 12027a (former) — Pre-recodification concealed carry (Q6)

[CS-10] Gov. Code § 12940 — California Fair Employment and Housing Act (FEHA); prohibition on disability and age discrimination in employment terms and conditions, including retirement benefits (Questions A, B, H)

[CS-11] Gov. Code § 53213.5 — Governmental plan fiduciary standards mirroring ERISA (Question C)

[CS-12] Gov. Code § 89503 — Gift limitations for public officials and employees (Question E)

[CS-13] Gov. Code § 19990 — Incompatible activities for state employees (Question E)

[CS-14] Evidence Code § 413 — Failure to produce evidence within a party’s control creates adverse inference (Question K)

[CS-15] Labor Code § 5803 — WCAB continuing jurisdiction to rescind, alter, or amend any order, decision, or award relating to disability; exclusive WCAB authority over permanent disability determinations; requires notice and opportunity to be heard (Question 13)

California Regulations

[CR-1] Cal. Code Regs. Title 8, § 15400.2 — Claim file retention; “shall not” be destroyed (Audit Box)

UC Internal Policies

[UC-1] UC Internal Audit Charter (Rev. September 2020) — “Full, free and unrestricted access” (Cover)

[UC-2] Regents Policy 7503 (January 25, 2018) — Compliance with State Audits (Cover)

[UC-3] UC Gold Book Policy GO 21-02, Section 1700.1 — Systemwide CCW policy (Q4, Q5, Q7)

[UC-4] UCLA PD Policy 209 (Lexipol, 2022) — Departmental CCW policy (Q4, Q5)

[UC-5] UC Group Insurance Regulations — Part IV, Section 6001-A (Q27)

[UC-6] UCRP — Disability and service retirement provisions (Q11–Q13, Q28, Q34)

[UC-7] UC Via Benefits Eligibility Rules — Footnote analysis (Q34)

IRS Authority

[IRS-1] IRS Form 1099-R Instructions — Distribution Codes 3, 2, and 7 (Q11–Q14)

[IRS-2] IRC § 72(t)(10) — Qualified public safety employee exception (Q13)

Case Law

[CL-1] Alberts v. Regents (Alameda Super. Ct., September 24, 2012) [unpublished] — CCW/DDI policy basis (Q7)

[CL-2] Jacobs v. Regents of the University of California (2017) 13 Cal.App.5th 17, Case No. B268758 — Cited by Chobanian (Q4, Q5)

[CL-3] United States ex rel. Shea v. eHealth, Inc., et al., No. 21-cv-11777 (D. Mass.) — DOJ False Claims Act and Anti-Kickback Statute complaint; Elevance Health named defendant; $230M in alleged kickbacks; motion to dismiss denied March 25, 2026 (Question G, Financial Context) | DOJ Press Release

[CL-4] United States v. Aon plc, Case No. 1:21-cv-01633 (D.D.C.) — DOJ antitrust action describing retiree exchange market as “two horse race” dominated by Willis Towers Watson (Question F, Financial Context) | DOJ Press Release

Documents referenced herein that were created by UC, issued by UC, filed by UC, retained by UC, or filed with the IRS under penalty of perjury, or generated by UC’s own contracted insurer, are UC’s own institutional record. Documents created by the undersigned were created in direct response to UC’s own records and communications. Where UC’s own institutional records are not produced to clarify this audit, the author will rely on California Evidence Code § 413, under which the failure to produce evidence within a party’s control permits the inference that such evidence would be adverse to the party withholding it.

Submitted for Regulatory Review and Public Accountability

Charles A. Harold Jr.
UCLA Police Department (Retired?), Badge #341
Founder and First President, Federated University Police Officers’ Association (FUPOA)

I affirm that the information contained in this document and its exhibits is true and accurate to the best of my knowledge and good faith belief, submitted under the protections of 31 U.S.C. § 3730(h) (False Claims Act anti-retaliation) and California Labor Code § 1102.5.