Fact Pattern:

Let's assume you are the newly hired NCAA Compliance Officer at Florida Sports College (FSC), a Division 1 University located outside Tallahassee, Florida. In your first week on the job, you receive a call from a news reporter at Wolf News Network who is doing an investigative report on sports betting by athletes at FSC, who are allegedly waging money on their own games, in violation of NCAA Rules Download NCAA Rulesand Regulations Download Regulations. The reporter explains to you that Wolf News received a file containing hacked computer records from 2 student athletes who were the victims of a phishing attack while using their computers in the FSC Library. The computer records show that these 2 athletes placed bets online on an FSC game in which they both played earlier this season. You consider the allegations to be credible and delicate.

Questions:

Please walk us through your considerations for conducting an internal investigation of the allegations, as follows:

1. 1. What potential internal and external threats could result from the Wolf News investigative report?
   2. What considerations are important for FSC as it considers what firm to hire as outside counsel for the investigation?

These are files:

College Sports Betting - NCAA Official Statement Ectle The NCAA opposes all forms of legal and illegal sports wagering on college sports. Sports wagering has become a serious problem that threatens the well-being of the student-athlete and the integrity of college sports. + The explosive growth of sports wagering has caused a noticeable increase in the number of sports wagering- related cases processed by the Association. + The Internet has made it easier than ever for student-athletes to place bets, providing easy access, virtual anonymity, and essentially no supervision. + Student-athletes are viewed by organized crime and organized gambling as easy marks. * When student-athletes gamble, they break the law and jeopardize their eligibility. * When student-athletes become indebted to bookies and can't pay off their debts, altemative methods of payment are introduced that threaten the well-being of the student-athlete NCAA Policy + The NCAA membership has adopted specific rules prohibiting student-athletes, athletics department staff members, and conference office staff from engaging in sports wagering (Bylaw 10.3). NCAA rules also prohibit non-athletics department staff members who have responsibilities within or over the athletics department, such as chancellors or presidents and faculty athletics representatives from engaging in sports wagering. NCAA national office employees are also prohibiting from engaging in sports wagering. + The rules against sports wagering applies to any institutional practice or competition (intercollegiate, amateur or professional) in an NCAA-sanctioned sport. + Sports competition should be appreciated for the inherent benefits related to participation of student-athletes, coaches, and institutions in fair contests, not the amount of money wagered on the outcome of the competition. + A student-athlete involved in sports wagering on the student-athlete's institution permanently loses all remaining regular-season and postseason eligibility in all sports. + A student-athlete who is involved in any sports wagering activity that involves college sports or professional athletics, through a internet gambling, bookmaker, a parlay card or any other method employed by organized gambling, will be ineligible for all regular-season and postseason competition for at least one year. Some NCAA Activities to Limit Sports Wagering + The NCAA also educates student-athletes and coaches on the dangers of sports wagering by producing information materials for them: conducting locker room visits; holding information sessions at annual compliance seminars; creating an interactive educational Web site on sports wagering for its student-athletes; and providing on-campus compliance officers with sports wagering educational resources. + Educational materials and resources are also distributed to officials and umpires across all NCAA sports. + The NCAA has developed a Web site to educate student-athletes, coaches, athletic administrators and the general public about NCAA rules about sports wagering. The Don't Bet on It Web site (www_dontbetonit.org) can be customized for the individual student-athlete by gender, sport and division. CBS basketball commentator Clark Kellogg, a former Ohio State University student-athlete, serves as host throughout the navigation of the site. + A companion video featuring Kellogg and ESPN broadcaster Beth Mowins was also created by the NCAA and will be distributed to student-athletes, coaches, athletic administrators and the general public prior to the 2008 Men's and Women's Final Fours + The NCAA works closely in sharing pertinent information on sports wagering and organized crime with the FBI and the U.S. Attorney General's advisory groups, the NFL, the NBA, the NHL, MLB, campus security officers, coaches associations, and campus student life personnel. + The NCAA has developed sports wagering curriculum for high schools, in conjunction with the National Federation of High Schools and the Florida Council on Compulsive Gambling, which was rolled out to high schools across the U.S. + The NCAA initiated conversation with gaming officials in Las Vegas and has reestablished those relationships, providing a better understanding of the wagering activity and trends on NCAA contests in sports books. Student-Athletes and Bracket Contests + NCAA member colleges and universities have defined sports wagering as putting something at risk such as an entry fee - with the opportunity to win something in return. Because of this, student-athletes, coaches and administrators may not participate in bracket competitions where there is both a required entry fee and an opportunity to win a prize. + Student-athletes and administrators may participate, under current NCAA rules, in bracket contests where there is no entry fee but a possibility of winning a prize. Some NCAA member schools, however, have chosen to ban student-athletes from participating in these types of bracket contests. Bracket Office Pools and Promotions + Office pools and similar games are illegal in most states, and we have learned that these types of pools are often the entry for youth to begin betting. + The NCAA is aware of office pools in excess of $100,000, and the magnitude of the revenue generated could negatively impact the spirit of the sport. + The NCAA wants to send a clear message that money does not have to be involved in order for the NCAA basketball tournament or other sporting contests to be fun. + The NCAA continues to work with its corporate champions and partners to encourage them to use other types of promotional games. When our partners have used bracket-focused promotions, we've insisted that a random drawing component be added. Internet Gambling Bill + In October 2006, President Bush signed legislation making it much more difficult to send money to Internet gambling sites. Any Internet casino that attempts to accept credit card payments, Internet bank transfers or any other illegal gambling payments will be blocked from doing so. The Act has placed significant roadblocks in the path of people who have become accustomed to easy access to online sports books. + The National Football League, Major League Baseball, the National Basketball Association and the National Hockey League joined the NCAA in sending a letter to Congress urging the passage of this legislation. Sports Wagering Study + NCAA President Myles Brand formed a national task force in 2004 to recommend strategies to counteract sports wagering among student-athletes and further analyze the data from the 2003 National Study on Collegiate Sports Wagering and Associated Health Risks. + This study represented the first effort to collect information on sports wagering and associated behaviors from a nationally representative sample of student-athletes. It was groundbreaking in both the scope of inquiry and in breadthumber of student-athletes participating (greater than 20,000 student-athletes across all divisions and most championship sports). + Key findings: Of 388 men's basketball players surveyed, 17 admitted to at least one of the following extreme gambling behaviors: taking money to play poorly in a game; knowing a teammate who took money to play poorly in a game; been threatened or harmed because of sports wagering; been contacted by an outside source to share inside information; actually providing inside information on a game.Of 2,000 football players surveyed, 102 admitted to at least one of the following extreme gambling behaviors noted above. + This research shows that no campus is immune to the problems of sports wagering. Every institution needs to review its sports-wagering education program to ensure it is reaching its student-athletes and the entire campus community. www.dontbetonit.org DON'T Sports Wagering RISK What student-athletes need to know. The NCAA is committed to protecting student-athlete well-being and the integrity of competition. NCAA sports wagering rules do not allow student- athletes or athletics employees (1) to bet THIS on any sport sponsored by the NCAA at any level, including college and/or professional or (2) to share information for sports wagering purposes. IF YOU RISK SOMETHING, IT'S A BET If you put something at risk (such as cash, entry fee, dinner or other tangible item) on any amateur and/or professional sporting event with a chance to win something in return, you violate NCAA sports wagering rules. NO SPORT WAGERS OF ANY KIND Types of sport wagers that violate NCAA rules include, but are not limited to, fantasy leagues, March Madness* brackets, Super Bowl squares, Calcuttas, sports pools, online sports bets, sports betting apps, parlay and prop bets, live in-game betting and single- game sports bets. PLAY WITH INTEGRITY 13 Student-athletes should NOT share any information CHALA about their team or any other team. This includes information regarding team disciplinary actions, strategy, injuries or team morale. This information is sought by gamblers. LOSING YOUR ELIGIBILITY Student-athletes who violate NCAA sports wagering rules will be ineligible for competition, subject to appeal to the Committee on Student-Athlete Reinstatement. Penalties will be considered on a case- by-case basis based on the guidelines for the division in which the student-athlete participates. NCAA ACHST Wagering Impacts Well-Being Sports wagering is a gateway for other behaviors that can negatively affect student-athlete well-being. Student-athletes reported wagering on Student-athletes reported wagering on sports within the last year. sports once a month or more - 5% 1% 24% Female - 9% Female Male Male 1 in 50 Student-athletes who wager 4% on sports placed their first bet male student-athletes meet before entering college. standard diagnostic criteria for problem gambling of male student-athletes who gambled in the past year reported one-day 90% gambling losses of $500 or more. Male 82% Female 26% of male student-athletes reported sports wagering as their first gambling activity. Student-athletes who reported wagering on sports placed 54% 31% 49% 23% wagers electronically. Male Female Male Female $ 32% 15% Student-athletes who think Student-athletes who bet Male Female sports wagering is a harmless on sports think they can pastime. Those figures are consistently make a lot of 76% and 61% for those money on the activity. who wager on sports. For additional information, please visit dontbetonit.org NCAA sports wagering contact: 317-917-6222 DON'T 24-hour confidential national gambling helpline: 800-522-4700 BET ON IT National Council on Problem Gambling: ncpgambling.org