Investigations

The College Sports Commission’s Department of Investigations (DOI) enforces the NCAA bylaws resulting from the House settlement. These rules govern institutional revenue sharing, noninstitutional or “third-party” NIL deals, and roster limits. The DOI conducts investigations to determine whether any rules violations occurred and enforces penalties, if imposed.

The NCAA’s Enforcement Staff remains responsible for investigating rules violations not connected to the House settlement, including allegations of recruiting or tampering violations, sports betting, and unethical conduct.

Investigations Staffing

The DOI staff includes attorneys, investigators, and analysts with backgrounds in litigation, investigations, and compliance.

Several team members are former Division I athletes.  They are familiar with the challenges of balancing high-level competition with the responsibilities of being a full-time student.

Investigative Approach

Routine Inquiries

The DOI conducts routine inquiries involving (1) unreported NIL deals, (2) unfulfilled deal obligations, and (3) the return of compensation for NIL deals not cleared after review via NIL Go. DOI sends inquiry forms to student-athletes via their institution’s compliance departments as part of this process. Student-athletes should work with their institution’s compliance representative to complete the form and answer questions from DOI. The compliance representative will coordinate the return of the completed form to DOI.

The DOI appreciates compliance departments that collaborate and respond promptly. In many instances, DOI may resolve an inquiry if it receives a fully completed form.

Positive and productive relationships with institutional partners are important for efficient investigations.

Complex Investigations

In addition to routine inquiries, DOI independently initiates and advances complex investigations into potential violations of the NCAA Bylaws governing NIL activity, revenue sharing, and roster limits.

Requests for Documents, Interviews and Information

In both routine and complex investigations, DOI may request documents and conduct interviews of institutional representatives, student-athletes, and other relevant witnesses, as appropriate.  DOI makes these requests to better develop facts and information to advance its investigations.

The DOI may also request interviews to collect background information related to witnesses’ former institutions, competing recruitment offers, and NIL-related business proposals.

Document requests and interviews are tools employed routinely throughout an investigation to assess potential violations, including reported trends or leads. They do not mean that the DOI has concluded that a rules violation occurred, nor necessarily indicate that the investigation is near completion.

The DOI expects and appreciates prompt cooperation when requesting interviews or the production of records consistent with the CSC’s cooperation policy and NCAA bylaws.

Cooperation

Student-athletes, institutions, and institutional officials have an obligation to cooperate fully and promptly with investigations conducted by the DOI, pursuant to NCAA Bylaws 23.2.7 and 19.2.1 . Full and timely cooperation is critical to the DOI’s investigations. It helps the DOI uncover the facts quickly and accurately, avoid unnecessary delays, and protect the integrity of the process for everyone involved.

Full and complete cooperation includes, but is not limited to:

  • Timely participation in interviews, and providing complete and truthful responses;
  • Timely and complete disclosure of relevant information or materials, in the format requested;
  • Providing access to electronic devices, social media accounts, messaging, or other accounts or applications that are or may be relevant to the investigation;
  • Instructing legal counsel, agents, and/or others acting on a party’s behalf to cooperate fully, including providing information and records regarding offers and agreements negotiated on behalf of the student-athlete; and
  • Encouraging family members, representatives of the institution’s athletic interests, and/or other associates to cooperate fully to the same extent.

Failure to fully cooperate may subject the student-athlete, institution, or institutional official to penalties.  Noncooperation may also serve as an aggravating factor that increases the penalty for other violations.

See below for the CSC’s policy on cooperation for institutions and institutional officials:

Information and Leads

Do you have information about a possible rules violation? Report it.  You do not need the whole story to report; smaller details may help DOI see a bigger picture and identify patterns worthy of further investigation.

Input from athletic department staff in particular on recruiting practices, agent misconduct, and questionable business proposals help the CSC apply the rules fairly by bringing potential violations to light. Athletic department staff are encouraged to self report NIL, revenue-share, and roster limit violations to the DOI in accordance to the rules.

Anyone with relevant information about potential revenue cap evasion, NIL-related violations, and roster limit noncompliance is encouraged to contact DOI.

Information may be submitted through the CSC’s Real Response Portal below: