California Gambling Control Commission Issues Critical Guidance on Stakeholder Communications and Ex Parte Rules

The California Gambling Control Commission (CGCC) has released a comprehensive new guide for stakeholders, outlining essential best practices for contacting the Commission and strictly warning against the legal pitfalls of “ex parte” communications.

As part of its ongoing commitment to transparency and its 2026 Strategic Plan, the Commission aims to streamline interactions while ensuring that all regulatory decisions are made on a complete, fair, and public record.

Navigating the Commission: Who to Contact

To ensure inquiries are handled efficiently, the Commission has identified key points of contact for various industry matters:

• Licensing & Approvals: For general licensing matters, stakeholders should contact Brian Gilleland, Deputy Director of the Licensing Division, at [email protected].

• Regulations & Legislation: Inquiries regarding laws or pending regulations should be directed to Nicole Learned, Deputy Director of Legislative and Regulatory Affairs, at [email protected].

• Evidentiary Hearings: For GCA hearing matters, contact the Presiding Officer noted in your hearing notice, or Administrative Hearings Coordinator Pam Mathauser at [email protected].

• Executive Leadership: All other high-level matters should be sent to Executive Director Lisa Wardall at [email protected].

The Danger of “Ex Parte” Communications

A central focus of the new guidance is the strict prohibition of ex parte communications—any communication regarding the merits of a pending application or request made without proper notice to all involved parties.

To comply with state rules, stakeholders must include Commission staff, Bureau staff, and the Applicant (or their designated agent) on all correspondence.

Crucial Warning: Stakeholders are strictly forbidden from sending communications of any kind directly to Commissioners regarding applications or pending decisions.

Why Compliance is Mandatory

The Commission warns that ex parte violations are not merely procedural errors; they pose a direct threat to the integrity of the gambling industry’s governance. Decisions made on incomplete or “private” information can lead to:

1. Application Denial: The Commissioners have the authority to deny an application or approval solely based on a prohibited communication.

2. Legal Reversals: Violations may breach the Bagley-Keene Open Meeting Act, potentially allowing opposing parties to overturn a decision that was previously taken in your favor.

3. Governance Risk: Transparency ensures that all parties—including the Bureau of Gambling Control—have access to the same record of information before a vote is cast.

“Transparency is a core tenet of good governance,” the Commission stated in the guidance. “Ex parte rules guarantee that all matters taken up by the Commission are conducted in a fair and transparent manner.”