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First Class Parking, LLC Valet Parking Operational (Period 12-5-17 to 12-10-17) (Design Miami and Art Basel Miami Beach 2017) 9-30-18MIAMI BEACH INTERNAL AUDIT REPORT City of Miami Beach, 1700 C onvention Ce nte r Drive, Miami Bea ch , Florid a 33139, www.miam ibeac hfl.gov Office of Internal Aud it Tel : 305-673-7020 TO: VIA: FROM : DATE: AUDIT : PERIOD: Jimmy L. Morales, City Manager Mark D. Coolidge, lntyf?r Internal Luis Medina, Auditor ~ September 30, 2018 First Class Parking , LLC Valet Parking Operational Audit December 5, 2017 through December 10, 2017 (Design Miami and Art Basel Miami Beach 2017) This report is the result of an audit of First Class Parking, LLC's valet parking operations during Design Miami and Art Basel Miami Beach 2017 which was held between December 5th and December 1 oth to determine their compliance with selected provisions in their signed concession agreement. INTRODUCTION The 2017 Design Miami event was held in a specially constructed tent located on the west side of the Miami Beach Convention Center preferred parking lot with the main entrance located near the intersection of Meridian Avenue and 19th Street. This event attracts the world 's top galleries who present museum-quality exhibitions of furniture , lighting and art objects. It opened on Tuesday, December 5th and continued to operate concurrently with Art Basel Miami Beach which was held from Wednesday, December 5 th through Sunday, December 1 oth . In addition, Art Basel Miami Beach 2017 was held at various City locations (Convention Center, Bass Museum of Art, New World Center, etc.) combining an international art show with a program of special exhibitions, parties and crossover events including music, film , architecture and design. Event attendance for Design Miami and Art Basel Miami Beach 2017 was reported to equal approximately 38,000 and 82,000 respectively. Patrons attend ing either event had the option to use the valet parking services provided by the City's concessionaire called First Class Parking, LLC. City Resolution No. 2010-27474 was adopted on September 15, 2010 authorizing First Class Parking, LLC to perform management and operation of valet parking services at the Miami Beach Convention Center, the Fillmore Miami Beach at the Jackie Gleason Theater and other City properties between October 1, 2010 and September 30, 2013. The concession agreement covered a multitude of terms including monthly fixed minimum rental payments, required insurance coverage, signage, performance bonds, property maintenance , etc. On September 11, 2013, the City Commission approved to exercise the agreement's additional two-year renewal option valid through September 30, 2015. With the Miami Beach Convention Center undergoing an unprecedented multiple year renovation project, the Finance and Citywide Projects Committee recommended approving a waiver of competitive bidding and awarding the current provider, First Class Parking, LLC, to continue operating for a term of three years or substantial completion of the project, whichever occurs first. The City Commission agreed with their recommendation and approved Resolution No. 2015- Page 1 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 28943 on March 11, 2015 authorizing the City Administration to negotiate an extension to the concession agreement. The extension to the concession agreement between the City and First Class Parking, LLC was executed on September 22, 2016 with the term of the agreement retroactively commencing on October 1, 2015 and expiring on September 30, 2018 or upon substantial completion of the project, whichever occurs first. The following table lists the daily number of valet parked vehicles by First Class Parking, LLC during the past six Design Miami and Art Basel Miami Beach events as reported by the concessionaire: Event Days (Actual Dates Vary) 2012 2013 2014 2015 2016 2017 Tuesday 94 86 79 Sl 136 39 Wednesday 649 63S 487 494 547 320 Thursday 497 492 S42 497 S88 347 Friday S83 sso S80 S63 663 379 Saturday 74S 777 622 73S 846 4SO Sunday S13 S96 S78 S61 623 42S Total 3,081 3,136 2,888 2,901 3,403 1,960 This significant decrease ( 42.40%) in 201 ?'s number of valet parked vehicles is most likely due to the Miami Beach Convention Center's ongoing construction and event patron's growing usage of various ride sharing service providers. OVERALL OPINION The City's valet parking concessionaire (First Class Parking, LLC) generally satisfied Design Miami and Art Basel Miami Beach 201 ?'s valet parking needs, regardless of the limited availability of parking spaces, building construction, traffic congestion, etc. Office of Internal Audit staff believes that the concessionaire, in conjunction with the City's Parking and Police Departments, performed sufficiently in overcoming many of these obstacles. Despite the successes achieved, there are still areas in need of improvement that can be of assistance in the planning of valet parking operations for Design Miami and Art Basel Miami Beach 2018 scheduled to start December 4, 2018. Shortcomings in the following areas were noted during testing and are described in detail in the section entitled "Findings, Recommendations and Management Responses". • The concessionaire provided valet operations data for the 2017 Design Miami/Art Basel events could not be completely relied upon to accurately determine their compliance with concession agreement section 12.1 's performance standard. • The concessionaire did not timely obtain a valid business tax receipt for the 2017 Design Miami/Art Basel Miami Beach events. • Shortcomings were noted concerning stored patrons' vehicles security. • The Parking Department did not always timely and accurately create the concessionaire's City Bills and five (5) were found to be backdated in the Munis System between November 2016 through March 2017. • The December 2017 supplied listing of concessionaire employee names and driver's licenses was incomplete in reference to City Code Section 18-340(6). Page 2 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 SCOPE, OBJECTIVES, AND METHODOLOGY The scope of this audit was to evaluate whether First Class Parking, LLC complied with selected terms in their concession agreement aimed at providing timely and quality professional valet services to Design Miami and Art Basel Miami Beach 2017 attendees. Although the audit covered the period December 5, 2017 through December 10, 2017, additional testing was performed on annual business tax receipts, concession fee payments, etc. that occurred since Design Miami/Art Basel Miami Beach 2016 to gain a better understanding of the concessionaire's overall performance. Consequently, this audit focused primarily on determining whether the following objectives were satisfied or achieved: 1. Confirm that First Class Parking, LLC (concessionaire) has complied with selected criteria outlined in the concession agreement. Examples of areas to be tested include comparing calculated turnaround times to stated goals, monitoring V.1.P. parking and the rates charged, assessing the performance of observed staff toward valet patrons, etc. 2. Confirm through observations that the concessionaire has implemented sufficient internal controls in their valet parking operations and followed valet parking guidelines established by the City. 3. Confirm that the concessionaire is current with their annual business tax receipt and has maintained sufficient insurance coverage. 4. Confirm that concession fees have been accurately and timely paid in accordance to the signed concession agreement. If not, determine whether the appropriate amount of late charges was levied and paid. This audit was conducted in accordance with the Standard Operating Procedures of the City of Miami Beach's Office of Internal Audit as well as internal audit best practices. They require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. The audit methodology included the following: • Reviewing selected provisions within the concession agreement between the City and First Class Parking, LLC. • Interviewing and making inquiries of staff to gain an understanding of the internal controls, assessing control risk, and planning audit procedures. • Performing substantive testing consistent with the audit objectives, including but not limited to examination, on a sample basis, of applicable transactions and records. • Drawing conclusions based on the results of testing, made corresponding recommendations, and obtaining auditee responses and corrective action plans. • Performing other audit procedures as deemed necessary. Page 3 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 FINDINGS, RECOMMENDATIONS AND MANAGEMENT RESPONSES During the Office of Internal Audit's physical observations, inquiries with key personnel and review of provided supporting documentation, the areas below were deemed in need of improvement with any repeat of prior year's findings denoted by an asterisk(*) in the left-hand margin. 1. * Finding -The Concessionaire Provided Valet Operations Data for the 2017 Design Miami/Art Basel Events could not be Completely Relied Upon to Accurately Determine their Compliance with Concession Agreement Section 12. 1 's Performance Standard Section 12.1 of the concession agreement specifically states the following: "Concessionaire acknowledges that timely acceptance and return of patron vehicles directly impacts patron's experience of Venue's serviced in this Agreement. As such Concessionaire agrees to ensure that not less than eighty percent (80%) of all vehicles parked for any Venue event shall be returned to patrons within twenty (20) minutes of patron's request for a vehicle (the "Performance Standard'). In the event Concessionaire fails to meet this standard for any Venue event, Concessionaire shall pay to the City a penalty in the amount of Forty and No/100 Dollars ($40. 00) for every vehicle delivered below the Performance Standard (the "Penalty'). " First Class Parking, LLC utilized Flash Parking's Flash Valet software application to manage valet parking volume and revenue. This cloud-based software allows the concessionaire to track vehicles in real time by providing a record of events associated with each parked vehicle, such as drop-off time, storage location, request time, and delivery time. Additionally, the software application gives the concessionaire the ability to accept credit card payments and retrieve summary data reports that provide the number of vehicles parked, daily reveri·ues earned from cash and credit cards, daily revenues earned per type of credit card (Visa, MasterCard, etc.), total revenue, individual vehicle and average vehicle retrieval times, etc. Both Parking Department and Office of Internal Audit (Internal Audit) staff have requested direct read only access to Flash Valet to allow designated City employees the ability to generate desired reports but have been denied due to additional licensing costs supposedly incurred. As a result, the City has to rely on the accuracy of the concessionaire's furnished reports. These retrieval times, also known as turnaround times, are times recorded in Flash Valet that measure the elapsed time from the patron's vehicle request until when the vehicle is returned to the patron. To determine whether First Class Parking, LLC complied with section 12.1 's performance standard, recorded turnaround times for the 2017 Design Miami/Art Basel events were requested. These requested times were used to calculate the corresponding percentage of turnaround times exceeding the twenty-minute benchmark using the Flash Valet data provided by the concessionaire. The data showed that the concessionaire had complied with section 12.1 's performance standard as 86.07% of vehicles parked during the 2017 Design Miami/Art Basel events were returned to the customer within the required twenty (20) minute threshold. The following table provides a summary of the results of the provided data: Page 4 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Total Number of Cars Retrieved within the Required 20 Minute Threshold: Total Number of Cars Retrieved over the 20 Minute Performance Threshold: Total Numberof Cars Parked Retrieved during Art Base I 12/05-12/10: 1,687 86.07% 273 13.93% 1,960 100.00% As a compensating internal control, Internal Audit staff randomly performed 220 turnaround times during the events and compared them to the Flash Valet data provided by First Class Parking, LLC to determine their accuracy. These turnaround times were calculated manually from Internal Audit staff's personal cell phones to the minute while Flash Valet calculates the actual time elapsed between when the transaction is entered into and closed out of the system. In addition, there could be time delays associated with the concessionaire's personnel in entering the information into Flash Valet due to the large volume of patrons, especially during high peak periods. Concessionaire staff was also observed at different periods closing out the turnaround time transaction when the requested vehicle was delivered to the entrance of the Fillmore ramp and not when the customer took possession which differs from section 12.1 's terms. Moreover, the concessionaire implemented a feature which allows valet patrons to send text messages in advance to request their vehicle to be delivered but Internal Audit staff would have unknowingly calculated the turnaround time from when the customer went to the valet pick-up tent to check on the status of their vehicle. Consequently, Internal Audit staff requested on April 5, 2018 a report of all vehicles that were requested by customers through texting which was received on June 28, 2018. The concessionaire's provided report of text requests showed that eleven (11) of the 220 performed turnaround times were requested by text and had positive differences. Positive differences were the result of Flash Valet turnaround times that showed a longer length of time as compared to Internal Audit's observations and calculations. It was noted that these positive differences, ranging from four ( 4) minutes to 27 minutes, may have occurred due to valet patrons requesting their vehicles through text and Internal Audit staff recording the request time when the patron arrived at the valet pick-up tent. Therefore, the eleven (11) calculated turnaround times requested by text messaging having positive differences were removed from our analysis which reduced our sample size from 220 to 209. Due to these possible time delays mentioned above, a standard deviation of two (2) minutes was permitted which resulted in a total of 133 of Internal Audit's calculated 209 turnaround times (63.64%) being deemed acceptable and were not further scrutinized. The remaining 76 calculated turnaround times, or 36.36%, differed from Flash Valet turnaround times ranging from three (3) minutes to an hour and twenty-four minutes with an average of seven (7) minutes. Of the remaining 76 compared vehicles' turnaround times, the following differences were noted: Page 5 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 a) 22 of these 76 turnaround times, or 28.95%, negatively differed by more than two (2) minutes. Negative differences were the result of Flash Valet turnaround times that showed a shorter length of time as compared to Internal Audit's direct observations. i. Five (5) of the 22 negative turnaround times were found to be duplicated transactions. All five (5) tickets were opened, but never closed; which meant that an end or delivery time was never recorded for the first time the ticket number was used. The same five (5) tickets were subsequently re- opened and closed with a minimal turnaround time by First Class management. During Internal Audit's visit to First Class Parking's offices, it was learned that the Flash Valet software application provides a report of every instance a ticket number is used to capture valet transaction information. Flash Valet's data records, initially provided by First Class Parking prior to visiting their offices, showed only the completed transaction with satisfactory turnaround times. The table in Exhibit A at the end of this report summarizes the five (5) turnaround times found to be duplicated transactions. The duplication of ticket numbers was previously mentioned in finding 2a of our 2016 audit report of the concessionaire's valet parking operations during the 2016 Design Miami/Art Basel events. Finding 2a states "Vehicles would occasionally have to be re-parked when valet customers would request their' vehicle and not appear timely at the valet pickup area. The concessionaire claims that these vehicles would then be re-entered into the Flash Valet system and corresponding duplicate reports would be generated for the re-parked vehicles, providing data for both the primary and secondary trips. Internal Audit had concerns that substandard turnaround times could be masked by having concessionaire staff re-park vehicles but the requested duplicate reports were never provided by the concessionaire." To help determine the pervasiveness of duplicate transactions, Internal Audit staff requested a report of all duplicate transactions for the 2017 Design Miami/Art Basel events. The data contained in the requested report would help the City make a better determination of First Class Parking's compliance with section 12.1 's performance standard. However, the concessionaire stated that their Flash Valet software did not have the capability to generate the requested report. Consequently, they requested the desired report from Flash Parking's support team but nothing has been provided to date. ii. The remaining seventeen (17) of the 22 negative turnaround times did not have a duplicate transaction; however, First Class Parking could not provide an explanation for these negative turnaround times. The root cause could not be determined as numerous possibilities exist to explain these differences ranging from inadvertent human error to an intentional Page 6 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 manipulation of the Flash Valet system. The table in Exhibit B located at the end of this report summarizes the seventeen ( 17) turnaround times found to negatively differ by more than two minutes. b) 54 of the 76 turnaround times, or 71.05%, positively differed by more than two (2) minutes. Positive differences were the result of Flash Valet turnaround times that showed a longer length of time as compared to Internal Audit's observations and calculations. First Class Parking was not able to explain the positive differences detected; however, it is important to note that positive turnaround time differences detected decreased the concessionaire's overall performance standard percentage and increased the likelihood that penalties could be levied. The table in Exhibit C located at the end of this report summarizes the 54 turnaround times found to positively differ by more than two (2) minutes. As a result of these deficiencies, First Class Parking's Flash Valet data provided for the 2017 Design Miami/Art Basel events is not completely reliable and it is difficult to make a determination regarding the concessionaire's compliance with section 12.1 's performance standard based on the current data. Recommendation( s ): Going forward, the concessionaire should accurately record the times that the event patron requests the vehicle and the actual time that they take possession of it which is currently when the transaction is closed out in the Flash Valet system. The time elapsed between these two times is considered the turnaround time which serves as the measure for the performance standard. If either of these two times is inaccurately recorded, then the corresponding turnaround time should not be relied upon. Furthermore, the concessionaire should provide the City a report of duplicate transactions for all events with an explanation as to why a second transaction was created. Additionally, the concessionaire should provide a report of all requests that were text messaged in advance so that these transactions can be compared to any turnaround times calculated by City staff and excluded from analysis in the future. Lastly, Parking Department administration should consider amending the current agreement and/or include in future valet concession agreements provisions granting authorized City staff read only direct access to the valet parking software system used. Although the finding above worked out to the concessionaire's detriment for 54 of the 76 reviewed turnaround times, it could easily be reversed in the future. Therefore, we believe that future contracts allow for the charging of a minimum penalty for the submission of inaccurate turnaround time data records. Concessionaire's Response: Concessionaire strongly disagrees with the Audit Department's finding. Audit Department's findings fail to recognize that the Concession Agreement does not to specify a methodology for the determination of compliance with the performance standard set forth in Sec. 12.1. It bears mentioning that the only reporting requirement set forth in the Concession Agreement is in Sec. 4. To clarify, Concessionaire has no contractual obligation to provide City with access to the Concessionaire's automated valet system on any basis. Notwithstanding the foregoing, Concessionaire has endeavored to provide City Page 7 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 with reports and limited access to its Flash Valet system to assist the City in the assessment of its performance. If further bears noting that the methodology employed by the City's Audit Department has also changed from year-to-year. For its 2017 audit, the City disregarded its own field observations which demonstrated Concessionaire's compliance with the Performance Standard. Instead, it relied exclusively on the data from Concessionaire's Flash Valet system data to determine compliance with the Performance Standard and assess substantial penalties for alleged non-compliance. While the data was apparently reliable enough last year to penalize the Concessionaire, now it is not-dependable enough to determine compliance. This determination of dependability is made by the Audit Department, notwithstanding the fact that the data provided by Concessionaire which diverges from the City's field audits is, in most cases, less generous in terms of the average turnaround time than those recorded by the City. Therefore, Concessionaire respectfully requests that the Audit Department's findings be revised to indicate the Concessionaire as "in compliance" with the standard set forth in Sec. 12.1. Please note that Concessionaire has committed to providing the Parking Department staff with unfettered, read-only access to the Flash Valet system as a condition of its soon to be negotiated Concession Agreement with the City. With respect to the timely recording of vehicle returns, Concessionaire disagrees with the Audit Department's finding and recommendation. Requiring the Concessionaire to leave transactions open until patrons accept their vehicles would unduly prejudice the performance of the Concessionaire for potential delays resulting from patron inaction. Concessionaire believes that the "turn-around time" is most accurately captured when we measure the time between the moment that the event patron requests the return of their vehicle and the actual time when the vehicle is returned to the valet ramp or pick-up area. Tying the performance measure to the "patron taking possession of the vehicle" would have the practical effect of reducing the actual time-period available to the Concessionaire to return the vehicle to the ramp and create an incentive for the Concessionaire to hurry- up the patron to take possession of the vehicle, thereby potentially jeopardizing their overall experience. Finally, Concessionaire believes that the Audit Department's suggested penalty for the submission of inaccurate "turnaround time" data records is misguided and unnecessary. The combined efforts of the Concessionaire and City are better spent defining the metric for performance to make the standard objective, so that both parties can easily comprehend it and agree on the appropriate way to measure and audit performance. Again, the mutual goal of the parties should be towards ensuring that MBCC patrons are receiving exceptional service that reflects well on both the City and event sponsors. City's Response (Parking Department): Regrettably, for compliance purposes, section 12.1 does not specify any methodology as to the performance standards. However, with this said, the Parking Department is currently negotiating a new agreement with the concessionaire. It has been agreed by both parties that due to the Flash Valet System used by the concessionaire having no means of recording the arrival time of the vehicle at the ramp; we will continue to record the performance when the customer takes possession of the vehicle and the transaction Page 8 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 is closed in the Flash Valet System. This will take effect until both parties agree to a more efficient solution hopefully in the near future. The second performance standard used will be the texting messag+ng, where Flash Valet has the functionality of recording the time the vehicle is requested by the customer and the time the ticket is closed. The Parking Department is currently negotiating fef a new Valet Concession Agreement. One of the provisions in the agreement is the Concessionaire will grant the City read only access to the Flash Valet System. It is worth mentioning that even though the new agreement is not in place, the Concessionaire has already given read only access to the City. Internal Audit Observation: The Office of Internal Audit acknowledges that a methodology to determine compliance with the performance standard set forth in section 12.1 is not clearly defined in the concession agreement. However, section 12.1 does require that the full vehicle population be used to determine the concessionaire's compliance with the Performance Standard as it specifically states, "Concessionaire acknowledges that timely acceptance and return of patron vehicles directly impacts patron's experience of Venue's serviced in this Agreement. As such Concessionaire agrees to ensure that not less than eighty percent (80%) of all vehicles parked for any Venue event shall be returned to patrons within twenty (20) minutes of patron's request for a vehicle (the "Performance Standard'). In the event Concessionaire fails to meet this standard for any Venue event, Concessionaire shall pay to the City a penalty in the amount of Forty and No/100 Dollars ($40. 00) for every vehicle delivered below the Performance Standard (the "Penalty')." It is agreed that the concessionaire should not be penalized when their requested vehicle . arrives and the customer is not present for whatever reason, nor should their staff hurry patrons to their vehicle thereby adversely impacting their experience at the event. However, the Flash Valet system data only currently captures the time that customers accepted possession of their vehicle as it does not record the time that the vehicles are delivered to the ramp. Consequently, there is no known means to determine the exact time that the 1,960 customers who utilized the concessionaire's valet services during the 2017 events actually had their vehicles delivered to the ramp. This measurement logic was similarly applied to last year's event during the audit process and it was not questioned by the concessionaire. Instead, they agreed to and paid the $7,520 performance penalty that resulted from these calculations plus additional interest resulting from their corresponding late payment. In addition, the confirmed duplication of ticket numbers was previously mentioned in finding 2a of our 2016 audit report of the concessionaire's valet parking operations during the 2016 Design Miami/Art Basel events. Internal Audit had concerns that substandard turnaround times could be masked by having concessionaire staff re-park vehicles, but the requested duplicate reports were never provided by the concessionaire and City staff was denied direct access to the system. It is true that Internal Audit's sample of turnaround times calculated at the 2016 Design Miami/Art Basel events did not yield material differences. Therefore, it was concluded that the 2016 turnaround time data submitted was sufficiently reliable to test the concessionaire's compliance with section 12.1 's performance standard based on this analysis. Page 9 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Several meetings have been recently held with the concessionaire about recording the time going forward that the vehicle is returned to the ramp, regardless of whether the customer is present. If able to be captured, then the Parking Department, Internal Audit and the concessionaire agreed that this would be a more equitable turnaround time in which to measure the concessionaire's performance in relation to the previously agreed upon 80% benchmark. In response, the concessionaire has determined an acceptable method to record when customers' vehicles have been returned to the valet ramp when they utilize their text messaging service. Unfortunately, they could not similarly determine a means to record the time in the Flash Valet system that the vehicle is delivered when the customer does not utilize the text messaging service. As a result, it was agreed that their performance for these vehicles will continue to be when the customer accepts possession of the vehicle and it is closed out in the Flash Valet system. On a positive note, the number of patrons using the text messaging service has been increasing over the past few years and the concessionaire's will continue to recommend its usage to patrons. 2. Finding -The Concessionaire did not Timely Obtain a Valid Business Tax Receipt for the 2017 Design Miami/Art Basel Miami Beach Events Section 3.4 of the concession agreement between the City and First Class Parking, LLC states "Concessionaire shall obtain, at its sole expense and responsibility, any business tax receipts required by the City for the proposed use(s) contemplated herein. To the extent required by the applicable sections of the City Code (as same may be amended from time to time), business tax receipts shall be obtained for each Venue serviced by Concessionaire pursuant to this Agreement." Additionally, City Code Section 102-357, pursuant to Section 205.042 of the 2017 Florida Statutes authorizes the City to levy a business tax for the privilege of engaging in or managing any business, profession or occupation within the City. Moreover, City Code Section 102-377 delineates the penalties and enforcement that the City may impose for violation of City Code Section 102-357. Lastly, City Code Section 102-370(b) states "If any business fails to obtain a business tax receipt required by this article, the manager, chief responsible executive and sales agent of the business shall each, jointly and severally, be responsible to take out the business tax receipt on behalf of the business. It shall be the duty of all officers of a corporation engaged in business in the city to see that such corporation complies with the provisions of this article, and they shall each personally be subject to the penalties imposed by this article for failure of a corporation to comply with the requirements of this article." To determine whether First Class Parking, LLC complied with the business tax receipt (BTR) requirement, the City's licensing and permitting software (EnerGov System) was searched to verify that the concessionaire obtained a BTR certificate for the 2017/18 fiscal year. Inquiries were also conducted with the Finance Department's Customer Service Division, which is tasked with issuing BTRs to businesses operating within the City, and the City's Parking Department, which is tasked with monitoring and approving valet operations. Page 10 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 As a result, it was concluded that the concessionaire paid for their 2017 /18 fiscal year BTR renewal on October 12, 2017; however, its status was recorded as "pending" in the EnerGov system. According to the notes entered in the corresponding BTR record, the concessionaire told the Customer Service Division that the number of locations in their agreement with the City had changed and that the BTR should reflect as such. The concessionaire's BTR was subsequently placed in pending status awaiting the outcome of the Customer Service Division's verification of the purported revisions. However, no records were found in EnerGov nor were any provided by the Customer Service Division to indicate that a verification was conducted and the concessionaire's account remained in pending status. Furthermore, an additional note on the BTR record indicated that the concessionaire was mistakenly issued a BTR certificate that was not valid. This note served to alert Customer Service representatives that the BTR certificate issued to the concessionaire had been annulled but had apparently not been recalled. Further complicating matters, the concessionaire, whether knowingly or not, provided the annulled BTR certificate to the Parking Department as proof of compliance with the City's BTR requirement. The Parking Department did not review the EnerGov System and accepted the certificate as valid and approved the concessionaire's valet operations for the 2017 Design Miami/Art Basel events. Internal Audit staff informed the Parking Department on May 21, 2018 that the concessionaire's BTR for their concession agreement with the City, was not issued and remains in "pending" status. Because of these deficiencies, First Class Parking, LLC did not possess a valid business tax receipt (BTR) during the 2017 Design Miami/Art Basel Miami Beach events and was not in compliance with Section 3.4 of the concession agreement and City Code Section 102-357. Although the Customer Service Division apparently did not follow-up with the concessionaire about the mistakenly issued BTR, the concessionaire was ultimately responsible to obtain a valid certificate as established in City Code Section 102-370(b ). Lastly, a review of the EnerGov system showed that the concessionaire was not issued a Code Compliance violation for not having a valid BTR as of June 28, 2018. These exceptions occurred primarily due to the Customer Service Division not following- up with the concessionaire regarding their mistakenly issued BTR and their need to submit their finalized locations; and that the Parking Department did not physically review the City's EnerGov permitting system. Recommendation( s ): Going forward, the Finance Department should not issue a BTR to a customer unless all requirements have been fully satisfied. As a compensating internal control, the Parking Department should verify in the EnerGov system that all valet companies' have been issued BTRs and not solely rely on any documents provided. In addition, the concessionaire should ensure that they timely adhere to the BTR requirement set forth in Section 3.4 of the concession agreement and City Code Section 102-357. Lastly, Code Compliance Department staff should have issued the concessionaire a violation for not having a valid BTR. Page 11of24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Concessionaire's Response: We strongly disagree with the Audit Department's finding. Concessionaire timely processed, tendered payment for, and was issued a BTR by the City on October 12, 2017, for the 2017-2018 fiscal year. A copy of the BTR provided is attached hereto and lists the MBCC as one of the identified locations. Issues identified by the Audit Department relate to the lack of internal controls or failures by the City to follow-up on open items strictly within its purview. Concessionaire had no actual notice of these pending issues and no reason to question of the validity of the BTR issued to it by the City. We strongly disagree that the Concessionaire should have been issued a violation for what plainly appears to be the City's error. City's Response (Finance Department): The Finance Department has implemented a procedure in which all BTRs issued by Customer Service Division staff are reviewed and approved by a supervisor. The department maintains a log of all BTR approvals. Additionally, the employee who issued this BTR is no longer employed by the City. As a result of this audit, as a compensating internal control, BTR renewals for First Class Parking LLC with regards to the valet concessionaire agreement with the City will be automatically routed to the Parking Department for review in the EnerGov System before they are released. City's Response (Parking Department): The Parking Department received a copy of the BTR from the concessionaire as it has customarily done in prior years. At no time was the Parking Department notified that it had been revoked. However, we have established that moving forward the Office Associate IV in the Parking Department will review the EnerGov System and approve the BTR for the valet concessionaire agreement. City's Response (Code Compliance Department): The Code Compliance Department was not informed of the change in status to the First Class Parking, LLC's BTR in October 2017. The EnerGov System does not alert staff to changes in status for BTRs, nor does it provide any other notifications for businesses in "Pending" status or a status other than "Active." To put this in perspective, a review of the Business License Module in the EnerGov System on October 8, 2018 found 6,348 licenses in "Pending" status and 2, 178 licenses in "Active" status. While the Code Compliance Department does actively check to ensure businesses are licensed to operate in the City, the Department focuses on inspecting the "high liability establishments" (i.e. massage parlors, tattoo shops, nail salons, adult entertainment establishments, nightclubs, etc.) in the first quarter of the fiscal year. Additionally, the Code Compliance Department has been working with Information Technology {IT) staff to develop a report that can be generated from EnerGov to alert staff to businesses that have not achieved an active BTR that can be prioritized. We began to utilize this report in late March of 2018, and the report was not distributed internally to our supervisory staff due to several issues, the primary issue was that it was pulling the data from the contacts, creating duplicate entries on the report. We continue to work with IT to improve the usefulness of the report to assist us in completing our mission. Page 12 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 3. * Finding -Shortcomings were noted Concerning Stored Patrons' Vehicles Security Despite concessionaire staff taking immediate action upon notification, Internal Audit staff's unannounced random walkthroughs of the temporary storage lots found the following occasions whereby the patrons' vehicles were not properly safeguarded thereby potentially exposing their contents to the weather and/or unscrupulous individuals: • The front passenger's side window was left down for ticket number 131388 on Friday December 8, 2017. • The front passenger's side window was left down for ticket number 126527 on Sunday December 10, 2017. • 56 of 264, or 21.21%, tested vehicles' doors were not locked in various lots throughout Art Basel Miami Beach 2017. • Keys to valeted vehicles blocking other stored vehicles were kept on top of the driver side rear tire to facilitate moving. Recommendation(s ): Concessionaire management should designate staff to periodically review the vehicles parked inside the lots to better ensure that they are all properly secured while in their possession. Furthermore, all vehicle keys should be safeguarded in one centralized location that is always monitored. Concessionaire's Response: Concessionaire has no basis for challenging the factual veracity of the Audit Department's findings. To avoid the recurrence of similar issues, security personnel assigned to each storage lot will be asked periodically (e.g. once every how or another designated interval) to inspect stored vehicles to ensure that all windows and doors are secured. Further, Concessionaire shall direct all valet personnel to cease the practice of leaving vehicle keys on driver side rear tires to facilitate the movement of certain blocked vehicles. City's Response (Parking Department): The Parking Department agrees with Internal Audit's recommendation. 4. Finding -The Parking Department did not Always Timely and Accurately Create the Concessionaire's City Bills and Five (5) were found to be Backdated in the Munis System between November 2016 through March 2017 Section 3.1.3 of the concession agreement between First Class Parking, LLC and the City establishes the payment terms for the third contract year which represents October 1, 2017 through September 30, 2018. Section 3.1.3 states "For all months where the MBCC (Miami Beach Convention Center) venue is not closed in the third contract year, the Concession Fee shall be $12,299.18 plus sales tax. For any month during the third contract year in which the MBCC venue is closed, the concessionaire shall receive a full abatement of the MBCC venue portion of the concession fee (which MBCC venue portion of the concession fee has been calculated at $7,810.43)." Additionally, section 3.1.4 sets forth the terms by which a true-up calculation is performed by the Parking Department which are summarized below. As part of this process, the concessionaire provided documents showing the vehicle volume change at the MBCC venue for the previous contract year. Then the Parking Department is tasked with determining the actual amount of concession fees due for the previous contract year Page 13 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 based on the vehicle volume change between the actual number of vehicles serviced at the MBCC venue during the previous contract year and those serviced during the contract base year; and true up the total amount of concession fees received for the previous contract year with the actual amount of concession fees due for the previous contract year based on the percentage change of the vehicle volume. True-up payments are to be submitted within thirty (30) days of the City's transmittal of written notice regarding the true-up calculation to the concessionaire. Furthermore, section 3.1 requires the concessionaire to submit the concession fee payment to the attention of the City Manager's designee (Parking Department) no later than the fifteenth (15th) day each month. Lastly, section 3.2 of the concession agreement states ''Any payment which Concessionaire is required to make to the City which is not paid on or before the due date provided for in this Agreement shall be subject to interest at the rate of eighteen (18%) percent per annum, or the maximum amount allowable under Florida law, whichever is less, from the due date of payment until such time as payment is actually received by the City." To determine whether First Class Parking, LLC complied with the provisions set forth in sections 3.1.3, 3.1.4, 3.1, and 3.2, Internal Audit searched the Munis System, the City's financial enterprise risk planning software application, and requested additional supporting documentation from the Parking Department. Subsequent inquiries with the City's Finance and Information Technology Departments provided further insight concerning the concessionaire's payments to the City. As a result, the following deficiencies were noted: a) First Class Parking, LLC's customer record in Munis showed an unpaid balance totaling $2,401.49. The Parking· Department mistakenly created City Bill #3608 for the full $12,007.41 concession fee even though the concessionaire should have only been billed the abated amount of $4,802.96. Nonetheless, the concessionaire timely paid the $12,007.41 associated with this invoice. When the Parking Department became aware of this $7,204.45 ($12,007.41 -$4,802.96) inadvertent overbilling and corresponding overpayment, they contacted the Finance Department to request applying the overage to the December 2016 invoice. Yet, the Parking Department created City Bill #4255 on 12/01/2016 in the amount of $12,007.41. However, the Finance Department misapplied $4,802.96 from the funds paid to City Bill #3608 instead of the requested $7,204.45. Additionally, the concessionaire was instructed by the Parking Department to pay $4,802.96 to City Bill #4255. This resulted in the concessionaire being invoiced $9,605.92 ($12,007.41 + $4,802.96-$7,204.45) by City Bill #4255 thereby leaving an unpaid balance of $2,401.49 ($7,204.45 -$4,802.96) in the Munis System. This unpaid amount remained incorrectly on the customer's record from 12/22/2016 until notified by the Office of Internal Audit. It was subsequently adjusted from the Munis System on 05/23/2018. b) The Parking Department created City Bill #6460 on 03/31/2017 for the concessionaire's 2015/16 true-up in the amount of $30,229.28 and inadvertently omitted sales tax from the invoice. Parking Department Administrative personnel became aware of this mistake and properly billed the concessionaire $32,345.33 ($30,229.28 + $2,116.05 (7% sales tax)) in City Bill #7267, on 05/15/2017. On Page 14 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 08/16/2018, the Parking Department provided a copy of an invoice adjustment request, dated 05/23/2017, as indication that the above-mentioned City Bill would be adjusted; however, the $30,229.28 invoice remained listed as outstanding. When questioned, Parking Department staff claimed that they hand delivered the invoice adjustment to the Finance Department but they did not request or maintain a time/date stamped copy for their records. Yet, Finance Department Administrative personnel could not locate any evidence that they had received the invoice adjustment request and claimed that it was apparently not submitted. Regardless of which account is true, this amount was adjusted from the Munis System on 03/08/2018 only after being notified by Internal Audit. c) Payment for City Bill #9223 was made by the concessionaire on 09/25/2017 which is ten (10) days after the concession agreement's specified due date. However, late payment interest in the amount of $55.34 was not billed to the concessionaire. d) The invoice dates for five (5) of the tested 29 invoices, or 17.24%, in the concessionaire's Munis System account were backdated ranging from one (1) to nineteen (19) days, meaning invoices were manually edited by Parking Department staff to indicate that they had been created earlier than they were. Subsequent inquiries with Finance Department personnel confirmed the ability of authorized employees to backdate City Bills in the Munis System. This shortcoming has been forwarded to Tyler Technologies, Inc. (the Munis System's parent company) for resolution but no corrective action has been taken to date. The Parking Department advised that the concessionaire attempted to pay City Bill #4772 (dated 01/02/2017 yet created on 01/06/2017) before the agreement's specified due date of the 15th of the month. However, City Bill #4772, created by a Parking Department employee contained an incorrect total amount. Subsequently, the concessionaire contacted the Parking Department to obtain a revised invoice with the correct total amount due. In response, City Bill #4772 was abated and replaced with City Bill #5114, dated 01/01/2017 but was created on 01/20/2017, invoiced the concessionaire for the January concession fee payment. The concessionaire remitted payment for City Bill #5114 on the next business day, 01/23/2017, and was subsequently billed late payment interest as the payment occurred after agreement's specified due date of the 15th of the month. Parking Department staff elected to prepare City Bill #5265 charging the concessionaire $17.71 in late payment interest for City Bill #5114's untimely remittance; however, the Parking Department provided City Bill #5114 on 01/20/2017. The concessionaire contested this amount and refused to pay. City Bill #5265's $17. 71 balance was abated by the Parking Department on 05/23/2018 upon being notified by the Office of Internal Audit. Page 15 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 In summary, the exceptions noted above occurred during the period November 2016 through March 2017 and stem from the untimely creation and backdating of concession fee payment invoices by Parking Department staff. It is important to note that the invoice creation date directly affects when the concessionaire will receive the concession fee bill and most likely when it is paid. Recommendation( s ): The Finance Department should continue to pursue the elimination of one's ability to backdate City Bills with Tyler Technologies, Inc. In the interim, it is recommended that the Parking Department continue to ensure concession fee payment invoices are created timely and are dated accurately. Going forward, the Parking Department should verify that all amounts mistakenly billed are promptly adjusted after becoming aware of the inaccuracy so that the concessionaire's Munis System payment record is accurately stated which also may adversely affect the annual issuance of their BTR. Additionally, the Finance Department should ensure that all invoice adjustment requests are accurately completed. Lastly, the Parking Department should invoice the concessionaire the $55.34 for their late payment of City Bill #9223. Concessionaire's Response Concessionaire has no comment with regard to this finding. Concessionaire looks forward to timely remitting payment upon the receipt of invoices from the City's Parking Department. City's Response (Parking Department): The Parking Department is not required und~r any section in this agreement to send an invoice to the Concessionaire. With this said, it is worth mentioning that under the new agreement, the Parking Department will no longer be issuing an invoice to the Concessionaire. Therefore, the incident mentioned above will not occur in the future. City's Response (Finance Department): a) The Finance Department inadvertently adjusted the invoice by $4,802.96, which was the amount indicated by the Parking Department for the new invoice. Finance adjusted the invoice on 05/23/2018 once notified of the error. d) The Finance Department is currently working with Tyler Technologies, Inc. to eliminate the ability for users to backdate City Bills in Munis. 5. * Finding -The December 2017 Supplied Listing of Concessionaire Employee Names and Driver's Licenses was Incomplete in Reference to City Code Section 18-340(6) City Code Section 18-340(6), entitled "Employees and valet operators code of conduct" states: "Valet operators shall submit to the parking department a list of all employees or contractors employed or retained by the valet operator who are engaged in valet services in the city. Additions and deletions to the valet employee roster shall be reported monthly. The employee report shall be submitted to the attention of the parking director no later than the fifth day of each month. The employee list shall contain the name of the employee or contractor and their valid Florida Driver's License numbers. A photocopy of each employee or contractor's valid Florida Driver's License shall be submitted for each employee or contractor on the roster." Page 16 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 To determine whether the concessionaire complied with City Code Section 18-340(6), a list of the concessionaire's employees, their corresponding driver's licenses and event time sheets were requested. Once provided, the list of the concessionaire's employees was compared to the event sign-in sheets to determine which employees worked the 2017 Design Miami/Art Basel event. Concurrently, an analysis was conducted of the concessionaire's employee driver's licenses to verify their validity. Lastly, a comparison of employee names found in the turnaround time data Flash Valet reports, provided by the concessionaire, to their provided list of employees was completed. In doing so, it was noted that twenty-three (23) additional employees' names were found in the turnaround time data reports provided by the concessionaire. These names did not appear on the provided employee roster, event sign-in sheets, and/or driver's license copies. Furthermore, seventeen (17) of these employees' names were listed as runners or employees whose position requires driving valet patrons' vehicles to and from the valet ramp and storage locations. Internal Audit staff contacted the concessionaire to determine the root cause as to why these names were omitted from the supplied listing of employee names and driver's licenses. The concessionaire advised that they would investigate the finding; however, no explanation has been provided to date. It is important to note that the listing of concessionaire employees and their corresponding driver's licenses as required in City Code Section 18-340(6) serves to mitigate the City's exposure to financial loss by helping ensure that valet employees possess valid driver's licenses to operate valet patron's vehicles. Although City Code Section 18-343(a)(2) does provide for escalating fines for repeated violations, none were issued during this event. Recommendation( s ): The concessionaire should prospectively furnish a complete listing and photocopies of all employee driver's licenses to the Parking Department by the fifth of each month or be subject to the penalties addressed in City Code Section 18-343(a)(2). The validity of each submitted driver license's information should be checked by the Parking Department with the valet company timely notified that any non-conforming employees are to be prohibited from working for the concessionaire as a runner/driver within the City until additional documentation is provided showing that the identified shortcomings have been resolved. Additionally, Parking Department personnel should periodically conduct site inspections to confirm that the actual valet employees working are the same as those for which names and driver's licenses were submitted. The appropriate enforcement actions should be taken for any differences found. Concessionaire's Response Concessionaire acknowledges the error with regard to the 17 employee names not included in the valet runner roster submitted to the City. This error is attributable to staff error entering the names of runners into the Flash valet system. Concessionaire will exercise more diligence in its future submittal of employee rosters to the Parking Department to ensure that all runner names and licensing information is properly reflected in such reports. Page 17 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 EXIT CONFERENCE Following the conclusion of this audit, several meetings have been held both internally and with the concessionaire to discuss the findings and an optimal resolution going forward as the identified issues also affect current contract negotiations and upcoming scheduled events. As a result, this report was not issued until all parties were in agreement as to its contents. F:\OBPl\$AUD\INTERNAL AUDIT FILES\DOC17-18\REPORTS -FINAL\First Class Parking LLC -Report 2017 09-30-18.docx cc: Kathie Brooks, Assistant City Manager Saul Frances, Parking Department Director John Woodruff, Chief Financial Officer Hernan Cardeno, Code Compliance Department Director Jorge Zuluaga, Chief Executive Officer, First Class Parking, LLC Page 18of24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit A Duplicated Negative Differences Internal Flash IA IA # Audit (IA} Valet (FV} Date Observed Observed Ticket# Ticket# Requested Completed . 1 131850 131850 12/09/2017 5:11 PM 5:27 PM 2 132623 132623 12/10/2017 5:18PM 5:35 PM 3 132079 132079 12/09/2017 5:55 PM 6:17 PM 4 131816 131816 12/09/2017 8:02 PM 8:23 PM 5 132050 132050 12/09/2017 5:57PM 6:20 PM IA Observed IA Calculated Retrieval FV Retrieval Retrieval Using Difference Time Notes Time FV Data Ticket reopened at 5:57 PM 0:16 ,o hrs 02 min 0:03 -00:13 and closed at 6:00 PM 0:17 ·o hrs 00 min 0:01 -00:16 Ticket reopened at 8:33 PM and closed at 8:34 PM 0:22 0 hrs 05 min 0:05 -00:17 Ticket reopened at 9:46 PM and closed at 9:51 PM 0:21 0 hrs 02 min 0:02 -00:19 Ticket reopened at 8:47 PM ' and closed at 8:49 PM 0:23 1o hrs 01 min: 0:01 -00:22 Ticket reopened at 8:48 PM and closed at 8:49 PM Page 19 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit B Non-Duplicated Negative Differences Internal Flash IA IA # Audit (IA) Valet (FV) Date Observed Observed Ticket# Ticket# Requested Completed 1 131030 131030 12/06/2017 7:09 PM 7:19 PM 2 126257 126257 12/07/2017 7:14PM 7:26PM 3 132008 132008 12/09/2017 5:51 PM 6:15 PM 4 132708 132708 12/10/2017 4:34 PM 4:38 PM 5 126205 126205 12/07/2017 6:15 PM 6:30PM 6 126213 126213 12/07/2017 7:14PM 7:23 PM 7 126234 126234 12/07/2017 7:33 PM 7:42 PM 8 126176 126176 12/07/2017 3:59 PM 4:21 PM 9 131930 131930 12/09/2017 6:15 PM 6:42 PM 10 131029 131029 12/06/2017 6:40 PM 6:59 PM 11 131994 131994 12/09/2017 5:31 PM 5:48PM 12 132102 132102 12/09/2017 4:23 PM 4:40PM 13 131150 131150 12/07 /2017 Stopwatch Stopwatch 14 126182 126182 12/07/2017 4:01PM 4:19 PM 15 131153 131153 12/06/2017 8:00PM 8:28 PM IA Observed IA Calculated Retrieval FV Retrieval Retrieval Using Difference IA Comments Time Time FV Data 0:10 0 hrs 07 min 0:07 -00:03 ·No explanation given. 0:12 O hrs 09 min 0:09 -00:03 No explanation given. 0:24 Ohrs 21 min 0:21 -00:03 No explanation given. 0:04 0 hrs 01 min 0:01 -00:03 No explanation given. 0:15 0 hrs 09 min 0:10 -00:05 No explanation given. Ticket information not 0:09 Ohrs 04min 0:04 -00:05 provided. No explanation given. 0:09 0 hrs 04 min 0:04 -00:05 No explanation given. 0:22 O hrs 15 min 0:15 -00:07 No explanation given. SMS request at 5:56 PM and 0:27 0 hrs 20 min 0:20 -00:07 closed at 6:16 PM. No explanation given. Ticket information not 0:19 O hrs 11 min 0:11 -00:08 provided. No explanation given. 0:17 .o hrs 09 min 0:09 -00:08 SMS requested at 5:25 PM 0:17 0 hrs 09 min 0:08 -00:09 No explanation given. Audit staff utilized a 0:30 0 hrs 20 min 0:20 -00:10 stopwatch to measure total elapsed turnaround time. 0:18 0 hrs 08 min 0:08 -00:10 No explanation given. SMS request per FV. No 0:28 0 hrs 14min 0:14 -00:14 further information provided. Page 20 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit 8 cont'd d ff1 erences Internal Flash IA IA # Audit (IA) Valet (FV) Date Observed Observed Ticket# Ticket# Requested Completed I 16 126188 126188 12/07 /2017i Stopwatch Stopwatch · 17 126142 126142 12/07 /2017 Stopwatch . Stopwatch IA Observed FV Retrieval IA Calculated Retrieval Time Retrieval Using Difference IA Comments Time FV Data I I :Audit staff utilized a 0:45 0hrs15 min. 0:15 -00:30 stopwatch to measure total I ;elapsed turnaround time. iAudit staff utilized a 1:25 ·O hrs 01 mini 0:01 -01:24 !stopwatch to measure total i elapsed turnaround time . . Page 21of24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit C Positive Differences Internal Flash IA IA IA Observed I IA Calculated #I Audit (IA) Valet(FV) Date Observed . FV Retrieva . . . Observed Retrieval . Retrieval Usmgl Difference I IA Comments Ticket# Ticket# Requested . Time Completed Time FV Data 1 131011 131011 12/06/2017 7:55 PM 8:00PM 0:05 Ohrs 08 min 0:08 0:03 'No explanation given. 2 131839 131839 12/09/2017' 4:47 PM 4:52 PM 0:05 Ohrs 08 min; 0:08 0:03 No explanation given. 3 132084 132084 12/09/201T 5:55 PM 6:13 PM 0:18 Ohrs 21 min• 0:21 <--- 0:03 ,No explanation given. 4 125767 125767 12/05/2017' 7:13 PM 7:15 PM 0:02 Ohrs 05 min: 0:05 0:03 :No explanation given. 5 132152 132152 12/09/2017: 6:15 PM 6:37 PM 0:22 Ohrs 25 min, 0:25 0:03 No explanation given. 6 131074 131074 12/06/2017; 7:39 PM 7:45PM 0:06 Ohrs09min · 0:09 0:03 No explanation given. 7 125766 125766 12/05/2017! 6:07 PM 6:10PM 0:03 0 hrs 06 min 0:06 0:03 . No explanation given. 8 131894 131894 12/09/2017 4:49PM 5:02PM 0:13 Ohrs 15 min. 0:16 0:03 •No explanation given. 9 132730 132730 12/10/2017 4:26 PM 4:39PM 0:13 .o hrs 15 min· 0:16 0:03 No explanation given. 10 131657 131657 12/08/2017 6:24PM 6:34PM 0:10 :0 hrs 12 min; 0:13 0:03 , No explanation given. ' 11 131520 131520 12/06/2017 5:46 PM 5:57 PM 0:11 :Ohrs 14 min 0:14 0:03 : No explanation given. 12 131899 131899 12/09/2017 5:18PM 5:29 PM 0:11 Ohrs 14 min 0:14 0:03 : No explanation given. 13 131432 131432 12/08/?017. 5:33 PM 5:44PM 0:11 :o hrs 14 min: 0:14 0:03 . No explanation given. '"; ... 14 131083 131083 12/06/2017 7:07PM 7:15 PM 0:08 !Ohrs 11 min 0:11 0:03 N.o explanation given. 15 126175 126175 12/07/2017 3:41 PM 3:49 PM 0:08 :0 hrs 11 min 0:11 t 16 131964 131964 12/09/2017! 5:00 PM 5:08PM 0:08 iOhrs 11 min 0:11 '" .. 17 126273 126273 12/07/2017! 6:45 PM 6:47 PM 0:02 . o hrs 06 min: 0:05 .. 18 132608 132608 12/10/2017 3:19 PM 3:25 PM 0:06 Ohrs 09 min 0:09 19 126244 126244 12/07/2017; 6:33 PM 6:33 PM 0:00 20 126245 126245 12/07/2017· 4:53 PM 4:54PM 0:01 . Page 22 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit C cont'd Positive Differences Internal Flash IA IA IA Observed I IA Calculated FV Retrieva #I Audit (IA) Valet (FV) Date Observed Observed Retrieval . Retrieval Using I Difference I IA Comments Time Ticket# Ticket# Requested Completed Time FV Data 21 131589 131589 12/06/2017 7:11 PM 7:16 PM 0:05 0 hrs 08 min 0:09 0:04 No explanation given. 22 131099 131099 12/06/2017 8:12 PM 8:14PM 0:02 Ohrs 07 min 0:06 0:04 No explanation given. 23 126252 126252 12/07/2017 6:29 PM 6:41 PM 0:12 Ohrs 16 min 0:16 0:04 No explanation given. 24 131600 131600 12/06/2017 6:36 PM 6:45 PM 0:09 Ohrs 12 min 0:13 0:04 No explanation given. 25 131326 131326 12/07/2017 6:26 PM 6:32 PM 0:06 .0 hrs 10 min 0:10 0:04 No explanation given. 26 126277 126277 12/07/2017 7:32 PM 7:33 PM 0:01 O hrs 05 min 0:05 0:04 No explanation given. 27 131129 131129 12/06/2017 8:23 PM 8:26 PM 0:03 0 hrs 08 min 0:08 0:05 No explanation given. 28 126190 126190 12/07/2017. Stopwatch Stopwatch 0:45 0 hrs 50 min 0:50 0:05 No explanation given. 29 131476 131476 12/08/2017 6:00PM 6:10 PM 0:10 0 hrs 15 min 0:15 0:05 No explanation given. 30 131571 131571 12/06/2017 6:26PM 6:36 PM 0:10 0hrs16 min 0:16 0:06 No explanation given. 31 132438 132438 12/10/2017 2:55 PM 3:02 PM 0:07 0hrs13 min 0:13 0:06 No explanation given. 32 131140 131140 12/06/2017 8:22 PM 8:26 PM 0:04 0 hrs 09 min 0:10 0:06 No explanation given. 33 132626 132626 12/10/2017 4:21 PM 4:33 PM 0:12 0hrs19 min 0:19 0:07 No explanation given. 34 131578 131578 12/06/2017 3:38PM 3:41 PM 0:03 0hrs11 min 0:10 0:07 ·No explanation given. 35 125768 125768 12/05/2017 7:48PM 7:48 PM 0:00 0 hrs 07 min 0:07 0:07 No explanation given. 36 131602 131602 12/06/2017 6:02 PM 6:03 PM 0:01 0 hrs 09 min 0:09 0:08 No explanation given. 37 131128 131128 12/06/2017 7:55 PM 8:06 PM 0:11 0 hrs 19 min 0:19 0:08 No explanation given. 38 131362 131362 12/08/2017 6:20 PM 6:23 PM 0:03 Ohrs 11 min 0:11 0:08 No explanation given. 39 132059 132059 12/09/2017 4:40PM 4:47 PM 0:07 0 hrs 16 min 0:16 0:09 No explanation given. 40 131534 131534 12/06/2017 7:28PM 7:34 PM 0:06 0 hrs 17 min 0:16 0:10 No explanation given. Page 23 of 24 Internal Audit Report First Class Parking, LLC Valet Parking Operational Audit Design Miami/Art Basel Miami Beach 2017 September 30, 2018 Exhibit C cont'd Positive Differences I Internal Flash IA IA IA Observed . I IA Calculated # I Audit (IA) Valet (FV} Date Observed b d . I FV Retrieva . I . I ff I IA Comments 0 serve Retrieva . Retrieva Usmg Di erence . Time Ticket# Ticket# Requested Completed Time FV Data 41 126455 126455 12/09/2017; 7:33 PM 7:35 PM 0:02 0:12 0:10 ! No explanation given. 42 131142 131142 12/06/2017: 8:04 PM 8:06PM 0:02 0:13 0:11 , No explanation given. 43 126279 126279 12/07/2017: 7:21 PM 7:26PM 0:05 0:17 0:12 No explanation given. 44 131132 131132 12/()6/2017; 8:03 PM 8:0SPM 0:02 0:14 0:12 No explanation given. 45 131557 131557 12/06/2017; 6:57 PM 7:02PM 0:05 0:18 0:13 No explanation given. 46 132423 132423 12/10/2017 1 2:35 PM 2:37PM 0:02 0:15 0:13 .. . ~ 47 131060 131060 12(06/20171 6:18 PM 6:20PM 0:02 0:15 0:13 48 131565 131565 12/06/2017j 6:50 PM 6:54PM 0:04 0:17 0:13 49 131063 131063 12/06/2017; 7:54 PM 8:00PM 0:06 0:20 0:14 so 131104 131104 12/06/2017: 6:43 PM 6:45 PM 0:02 0:17 0:15 No explanation given. ' ' f '~ ~ 51 132593 132593 • 12/10/2017! 3:54 PM 4:03PM 0:09 0:26 0:17 No explanation given. 52 132589 132589 12/10/2017) 4:20 PM 4:23 PM 0:03 Ohrs 20 min 0:20 0:17 No expl~nation given. ·'-c 53 131109 131109 12/06/2017: 6:32 PM 6:33 PM 0:01 Ohrs 19 min 0:19 0:18 No explanation given. 54 132123 132123 , 12/09/2017! 8:05 PM 8:11 PM 0:06 Ohrs 24min 0:25 0:19 No explanation given. Page 24 of 24