COWLITZ TRIBAL GAMING COMMISSION (2026)

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COWLITZ TRIBAL GAMING COMMISSION

Tribal Internal Control Standards

CTGC-REG-2026-01

Revised May 26, 2026

Adopted by Commission Resolution 2026-01

CHAPTER 1

OVERVIEW .................................................................................................................................... 3

CHAPTER 2

DEFINITIONS ................................................................................................................................. 4

CHAPTER 3

GENERAL STANDARDS ................................................................................................................ 12

CHAPTER 4

BINGO MINIMUM INTERNAL CONTROL STANDARDS .............................................................. 16

CHAPTER 5

CARD GAMES .............................................................................................................................. 24

CHAPTER 6

GAMING PROMOTIONS & PLAYER TRACKING ............................................................................. 28

CHAPTER 7

TABLE GAMES ............................................................................................................................. 30

CHAPTER 8

ELECTRONIC GAMING SYSTEMS .................................................................................................. 37

CHAPTER 9

COMPLIMENTARY SERVICES & ITEMS ......................................................................................... 62

CHAPTER 10

CAGE, VAULT, KIOSK, & CASH EQUIVALENTS .......................................................................... 63

CHAPTER 11

INFORMATION TECHNOLOGY & DATA .................................................................................... 70

CHAPTER 12

SURVEILLANCE ........................................................................................................................ 75

CHAPTER 13

DROP & COUNT MINIMUM INTERNAL CONTROL STANDARDS ............................................... 81

CHAPTER 14

AUDITING & ACCOUNTING ..................................................................................................... 93

CHAPTER 15

AUDITING REVENUE ............................................................................................................... 97

CHAPTER 16

PROGRESSIVE JACKPOT STANDARDS .................................................................................... 103

CHAPTER 17

TITLE 31 COMPLIANCE .......................................................................................................... 106

CHAPTER 18

KENO .................................................................................................................................... 111

CHAPTER 19

SPORTSBOOK........................................................................................................................ 119

CHAPTER 20

PATRON DEPOSIT ACCOUNTS & CASHLESS SYSTEMS ............................................................ 132

CHAPTER 21

LINES OF CREDIT ................................................................................................................... 134

CHAPTER 22

ELECTRONIC TABLE GAMES................................................................................................... 136

Chapter 1

1.1.

Authority

1.2.

1.3.

OVERVIEW

The Cowlitz Tribal Gaming Commission, under authority of the Indian Gaming

Regulatory Act of 1988, utilizing the National Indian Gaming Commission’s

Minimum Internal Control Standards (MICS), the 25 CFR Part 542, 543 and 547

regulations as a framework to create regulations to be known as Tribal Internal

Control Standards (TICS).

Scope

These regulations contain standards and procedures that govern cash handling,

documentation, game integrity, auditing, surveillance, information technology,

complimentary services or items, gaming promotions and player tracking

systems, drop and count, as well as other areas. MICS 542.3(c)

Also contained in the TICS are standards for currency transaction reporting in

accordance with 31 CFR Part 1021 (Effective March 1, 2011).

Order of Resolution

How do these regulations affect the Class III gaming minimum internal control

standards established in the Tribal-State Compact? MICS 542.4

If there is a direct conflict between the Tribal-State Compact and this

document, then the Tribal-State Compact shall prevail.

If the Tribal-State Compact provides a level of control that equals or

exceeds the level of control under this document, then the Tribal-State

Compact standard shall prevail.

If this document provides a level of control that exceeds the level of

control under the Tribal-State Compact, then this document shall prevail.

Chapter 2

2.1.

DEFINITIONS

The following are definitions for terms used in this document.

Accountability means all financial instruments, receivables, and patron deposits constituting the total

amount for which the bankroll custodian is responsible at a given time.

Accumulated Credit Payout means credit earned in an Electronic Gaming Machine that is paid to a

customer via a cash-out ticket.

Actual Hold Percentage means the percentage calculated by dividing the win by the drop. Can be

calculated for individual games or type of games on a per-day or cumulative basis.

Agent (or employee, staff, personnel, team member) means a person authorized by the gaming

operation, as approved by the TGA, to make decisions or perform assigned tasks or actions on behalf of

the gaming operation.

AICPA means the American Institute of Certified Public Accountants.

Annual means one full calendar year; not to exceed 15 months

Automated payout means payment issued by a machine.

Bank or Bankroll means the inventory of currency, coins, chips, and cash equivalents in the cage, pit

area, cashiering locations, and on the playing tables and cash in bank which is used to make change, pay

winnings, bets, and pay electronic game jackpots.

Cage means a secure work area within the gaming operation for cashiers, which may include a storage

area for the gaming operation bankroll.

Cage Accountability Form or Accountability Form means an itemized list of the components that

make up the cage accountability.

Card Games means a game in which the gaming operation is not party to wagers and from which the

gaming operation receives compensation in the form of a rake-off, a time buy-in, or other fee or

payment from a player for the privilege of playing.

Card Room Bank means the operating fund assigned to the card room or main card room bank.

Cash equivalents means a treasury check, personal check, travelers check, wire transfer of funds,

money order, certified check, cashier’s check, a check drawn on the Tribal Gaming Operation payable to

the patron or to the Tribal Gaming Operation, or a voucher recording cash drawn against a credit card or

charge card.

Cashless system means a system that performs cashless transactions and maintains records of those

cashless transactions.

Cashless transaction means a movement of funds electronically from one component to another.

Cash-Out Ticket means an instrument of value generated by an EGM representing a monetary amount

owed to a customer at a specific electronic gaming machine. This investment may be wagered at other

machines by depositing the cash-out ticket in the machine document acceptor.

Chair of NIGC means the Chair of the National Indian Gaming Commission.

Chip means a money substitute, in various denominations, issued by a gaming establishment and used

for wagering.

Chip Tray means that container located on gaming tables where chips are stored that are used in the

game.

Class II gaming means Class II gaming has the same meaning as defined in 25 U.S.C. 2703(7)(A).

Class III gaming means gaming that is govern by the Tribal-State Compact

Class II gaming system means all components, whether or not technologic aids in electronic, computer,

mechanical, or other technologic form, that function together to aid the play of one or more Class II

games, including accounting functions mandated by these regulations or part 547 of this chapter.

Complimentary services and items (or Comps) means services and items provided to a patron at the

discretion of an agent on behalf of the gaming operation or by a third party on behalf of the gaming

operation. Services and items may include, but are not limited to, travel, lodging, food, non-alcoholic

beverages, or entertainment expenses.

Count means the act of counting and recording the drop and/or other funds. Also, the total funds

counted for a particular game, player interface, shift, or other period.

Count room means a secured room where the count is performed in which the cash and cash

equivalents are counted.

Coupon means a financial instrument of fixed wagering value that can only be used to acquire noncashable credits through interaction with a voucher system. This does not include instruments such as

printed advertising material that cannot be validated directly by a voucher system.

CPA means Certified Public Accountant. Professional accountant(s) who is qualified and sufficiently

independent to act as auditor of the tribal gaming operations.

Credit-In Meter means a meter that records the amount wagered as a result of credits played.

Credit Slip means a form used to record the return of chips from a gaming table to the cage.

CTGC means the Cowlitz Tribal Gaming Commission.

Currency cassette means a compartment that contains a specified denomination of currency. Currency

cassettes are inserted into kiosks, allowing them to dispense currency.

Dealer/Boxperson means an employee who operates a game, individually or as a part of a crew,

administering house rules and making payoffs.

Dedicated camera means a video camera that continuously records a specific activity.

Download package means approved data sent to a component of a gaming system for such purposes

as changing the component software.

Drop means the total amount of cash and/or cash equivalent removed from the drop box.

Drop Box means a locked container attached to a gaming station, EGM or remote point of sales in

which cash or cash equivalents are placed at the time of a transaction.

Drop Box Cabinet means the wooden or metal base of the gaming machine that contains the gaming

machine drop box.

Drop Box Contents Key means the key used to open drop boxes.

Drop Box Release Key means the key used to release drop boxes from gaming station or EGM.

Drop Box Storage Rack Key means the key used to access the storage rack where drop boxes are

secured.

Drop period means the period of time that occurs between sequential drops.

Drop Proceeds means the total amount of financial instruments removed from drop boxes and

financial instrument storage components.

Electronic Gaming Machine or EGM means an electronic or electromechanical device that allows a

player to play games of chance. Such device is activated by the insertion of a ticket, currency or credit

purchased currency and awards game credits or a written statement of the player’s accumulated

credits, which written statements are redeemable for cash.

Electromagnetic interference means the disruption of operation of an electronic device when it is in

the vicinity of an electromagnetic field in the radio frequency spectrum that is caused by another

electronic device.

EPROM means erasable Programmable Read Only Memory—a non-volatile storage chip or device that

may be filled with data and information, that, once written, is not modifiable, and that is retained even

if there is no power applied to the system.

Exception report means a listing of occurrences, transactions or items that fall outside a

predetermined range of acceptability.

Financial instrument means any tangible item of value tendered in game play, including, but not

limited to bills, coins, vouchers, and coupons.

Financial instrument storage component (or Drop Box) means any component that stores financial

instruments, such as a drop box, but typically used in connection with player interfaces.

FinCEN means Financial Crimes Enforcement Network, Department of the Treasury.

Fill means a transaction whereby a supply of cash, chips or coins is transferred from the cage to a table

game, cashier station, bingo, pull tab, OTB, or keno department.

Fill Slip means a document evidencing a fill.

Game software means the operational program or programs that govern the play, display of results,

and/or awarding of prizes or credits for games.

Gaming system means all components, whether or not technologic aids in electronic, computer,

mechanical, or other technologic form, that function together to aid the play of Class II and Class III

games, including accounting functions mandated by these regulations or part 547 of this chapter.

Gaming equipment means all electronic, electro-mechanical, mechanical, or other physical

components utilized in the play of games.

Gaming promotion means any promotional activity or award that requires game play as a condition of

eligibility.

Gaming means staking or risking something of value upon the outcome of a contest of chance or a

future contingent event not under the person's control or influence, upon an agreement or

understanding that the person or someone else will receive something of value in the event of a certain

outcome.

Generally Accepted Accounting Principles (GAAP) means a widely accepted set of rules, conventions,

standards, and procedures for reporting financial information, as established by the Financial

Accounting Standards Board (FASB), including, but not limited to, the standards for casino accounting

published by the American Institute of Certified Public Accountants (AICPA).

Generally Accepted Auditing Standards (GAAS) means a widely accepted set of standards that

provide a measure of audit quality and the objectives to be achieved in an audit, as established by the

Auditing Standards Board of the American Institute of Certified Public Accountants (AICPA).

Governmental Accounting Standards Board (GASB) means generally accepted accounting principles

used by state and local governments.

Gross Gaming Revenue means annual total amount of money wagered on Class II and Class III games

and admission fees (including table or card fees), less any amounts paid out as prizes or paid for prizes

awarded.

Hardware means gaming equipment.

Hold means the relationship of win to credit or ticket-in for EGM’s and win to drop for table games.

Imprest Basis means a method of accounting for a cash or cash equivalent bank such that the expected

value remains a constant, fixed, and known amount.

Independent means the separation of functions to ensure that the agent or process monitoring,

reviewing, or authorizing the controlled activity, function, or transaction is separate from the agents or

process performing the controlled activity, function, or transaction.

Inspector means an employee of the Tribal Gaming Agency duly appointed by the agency as an

Inspector.

Internal Audit means individuals who are independent of gaming operations with respect to the

departments subject to audit (auditors internal to the operation, officers of the TGRA, or outside CPA

firm may perform this function). Internal auditor(s) report directly to the Tribe, TGRA, audit committee,

or other entity designated by the Tribe.

Jackpot Payout means the portion or amount of a jackpot paid by EGM personnel.

Kiosk means a device capable of redeeming vouchers and/or wagering credits or initiating electronic

transfers of money to or from a patron deposit account.

Main Card Room Bank means a fund of currency, coin, and chips used primarily for poker card game

areas. Used to make even money transfers between various games as needed. May be used similarly in

other areas of the gaming operation. May also be known as the Cage Poker Window.

Manual payout means any non-automated payout.

Master Game Program Number means the game program number listed on an EGM EPROM, or other

equivalent game software media.

Master Game Report means a form used to record, by shift and day, each table game’s winnings and

losses. This form reflects the opening and closing table inventories, the fills and credits, and the drop

and win. This form is also known as the “stiff sheet.”

MICS means minimum internal control standards in this part.

Modification means a revision to any hardware or software used in a gaming system.

Network communication equipment means a device or collection of devices that controls data

communication in a system including, but not limited to, cables, switches, hubs, routers, wireless access

points, landline telephones and cellular telephones.

NIGC means the National Indian Gaming Commission, established by the Indian Gaming Regulatory Act,

25 U.S.C. 2701 et seq.

Non-cashable credit means credits given by an operator to a patron; placed on a Class II or Class III

gaming system through a coupon, cashless transaction or other approved means; and capable of

activating play but not being converted to cash.

Openers and Closers means the forms used by gaming operation supervisory personnel to document

the inventory of chips and coins on a table at the beginning and ending of a shift and by Accounting to

calculate the Table Games win/loss. Also known as a table inventory form/slip.

Patron means a person who is a customer or guest of the gaming operation and may interact with a

game. Also may be referred to as a “player.”

Par Percentage means the percentage of each dollar wagered that the house wins (i.e., gaming

operation advantage).

Par Sheet means a manufacturer’s specification sheet for an electronic lottery game that provides game

payouts by type, count, and percentage.

Payout means a transaction associated with a winning event.

PIN means the personal identification number used to access a player's account.

Pit Supervisor means the employee who supervised all games in a pit.

Player Account Server means a system used by a gaming operation to monitor EGM activity on an

online basis.

Player interface means any component(s) of a gaming system, including an electronic or technologic

aid (not limited to terminals, player stations, handhelds, fixed units, etc.), that directly enables player

interaction in a Class II or Class III game.

Player Supported Jackpot (PSJ) means a separate contest of chance directly related to the play or

outcome of an authorized Table Game, Tribal Lottery System, or Electronic Bingo game. In PSJs,

operations: (a) Collect funds from the players' wagers (the pot) for a separate prize; and (b) Act only as

the custodian of the PSJ funds, including any interest earned on this money; and (c) Maintain no legal

right to the funds, except for administrative fees; and (d) Must strictly account for all funds.

Player Tracking System means a system used in gaming departments to record the gaming activity of

individual patrons.

Primary and Secondary Jackpots means promotional pools offered at certain card games that can be

won in addition to the primary pot.

Prize payout means payment to a player associated with a winning or qualifying event.

Progressive prize means a prize that increases by a selectable or predefined amount based on play of a

game.

Progressive Electronic Gaming Machine means an EGM, with a payoff indicator, in which the payoff

increases as it is played (i.e., deferred payout). The payoff amount is accumulated, displayed, and

remains until a player attains the pre-determined event that results in the progressive amount being

paid.

Progressive Jackpots means deferred payout from a progressive EGM or table game.

Progressive Table game means table games that offer progressive jackpots.

Promotional Payouts generally means personal property or awards given to players by the gaming

operation as an inducement to play. Promotions vary but a promotion example might be a program

developed where a player receives a form of personal property based on the number of games or

sessions played.

Promotional Progressive Pots/Pools means funds contributed to a game by and for the benefit of

players that are distributed to players based on a predetermined event.

Proposition Player means a person paid a fixed sum by the gaming operation for the specific purpose

of playing in a card game. A proposition player makes wages with her/his own funds, retains her/his

winnings, and absorbs her/his losses.

Rake means a commission charged by the house for maintaining or dealing a game such as poker.

Rake Circle means the area of a table where the rake is placed.

Random number generator (RNG) means a software module, hardware component or combination of

these designed to produce outputs that are effectively random.

Reflexive software means any software that has the ability to manipulate and/or replace a randomly

generated outcome for the purpose of changing the results of a game.

Removable/rewritable storage media means program or data storage components that can be

removed from gaming equipment and be written to, or rewritten by, the gaming equipment or by other

equipment designed for that purpose.

Request for Fill means a form that is used to request the transfer of chips and/or coin from the cage to

a table. The request precedes the actual transfer transaction that is documented on a fill slip.

Request for Credit means a form that is used to request the transfer of chips from a table to the cage.

The order precedes the actual transfer transaction that is documented on a credit slip.

Runner means a gaming employee who transports chips/cash between a gaming table and a cashier.

Server means a computer that controls one or more applications or environments within a gaming

system.

Seed Money means a beginning jackpot amount (also known as a base amount) added to a progressive

meter which the operation funds, but maybe recovered by the operation through player funds once per

seed amount the operation contributes.

Shift means a time period, unless otherwise approved by the Tribal Gaming Agency, not to exceed 24

hours.

Shill Funds means financing provided by the gaming operation to a proposition player.

Signature (as required upon any record or document) means the legible recording in script of not less

than a person’s first initial, last name, and certificate or permit number.

Soft Count means the count of the contents in a drop box or currency acceptor.

Sufficient clarity means the capacity of a surveillance system to record images at a minimum of 20

frames per second or equivalent recording speed and at a resolution sufficient to clearly identify the

intended activity, person, object, or location.

Surveillance operation room(s) means the secured area(s) where surveillance takes place and/or

where active surveillance equipment is located.

Surveillance system means a system of video cameras, monitors, recorders, video printers, switches,

selectors, and other equipment used for surveillance.

SICS (System of Internal Control Standards) means an overall operational framework for a gaming

operation that incorporates principles of independence and segregation of function, and is comprised of

written policies, procedures, and standard practices based on overarching regulatory standards

specifically designed to create a system of checks and balances to safeguard the integrity of a gaming

operation and protect its assets from unauthorized access, misappropriation, forgery, theft, or fraud.

Table Games means games that are banked by the house or a pool whereby the house or the pool pays

all winning bets and collects from all losing bets.

Table Inventory means total coins and chips at a Table.

Table Inventory Form means the document where chips and funds held at a table are recorded when

table inventory is taken. Also known as a table inventory slip and openers and closers.

Test/diagnostics mode means a mode on a component that allows various tests to be performed on

the gaming system hardware and software.

Testing lab means an organization recognized by a TGA pursuant to § 547.5(f) and the Tribal-State

Compact.

TGA means the Tribal Gaming Agency, which is the entity authorized by tribal law to regulate gaming

conducted pursuant to the Indian Gaming Regulatory Act.

TGO means the Tribal Gaming Operations (operation or gaming operation) refers to the Ilani Casino.

Theoretical Hold means the intended hold percentage or win as computed and referenced to its

payout schedule or par sheet.

Theoretical Hold Worksheet means a worksheet provided by the manufacturer that indicates the

theoretical percentages that the gaming device should hold based on exhaustive play.

Tier A means gaming operations with annual gross gaming revenues of more than $3 million but not

more than $8 million.

Tier B means gaming operations with annual gross gaming revenues of more than $8 million but not

more than $15 million.

Tier C means gaming operations with annual gross gaming revenues of more than $15 million.

TICS means the Tribal Internal Control Standards established by the TGA that are at least as stringent as

the standards set forth in the Tribal State Compact and 25 CFR Part 542 and 543.

Tribal-State Compact means an agreement between a tribe and a state to govern the conduct of Class

III gaming

Vault means a secure area where cash and cash equivalents are stored.

Voucher means a financial instrument of fixed wagering value, usually paper, that can be used only to

acquire an equivalent value of cashable credits or cash through interaction with a voucher system.

Voucher system means a system that securely maintains records of vouchers and coupons; validates

payment of vouchers; records successful or failed payments of vouchers and coupons; and controls the

purging of expired vouchers and coupons.

Wide Area Progressive Electronic Gaming Machine means a Class II progressive EGM that makes

deferred payouts where individual machines are linked to machines in other operations and all the

machines affect the progressive amount. As money is inserted into a single machine, the progressive

meter on all of the linked machines increases.

Win means the net win resulting from all gaming activities. Net win results from the total amount of

gaming income (gross gaming revenue) after prizes or winnings have been paid out; i.e., the difference

between the total amount wagered or played and the amounts repaid to the winners.

WSGC means the Washington State Gambling Commission

Chapter 3

GENERAL STANDARDS

3.1.

System of Internal Control Standards (SICS) MICS 542.3(d)

3.2.

The Tribal Gaming Operations (TGO) must develop and implement a System of

Internal Control Standards (SICS) that, at a minimum, complies with the TICS.

Initially and upon each subsequent update of the SICS, TGO shall submit the SICS

document to the Tribal Gaming Agency for review, discussion, and approval.

All changes necessary to ensure compliance with the TICS must be promulgated

and implemented no later than 30 days after final approval by TGA.

Alternate Minimum Standards MICS 542.18

The gaming operation may request an alternate standard from those set forth in

the TICS if the gaming operation:

Determines that it is unable to comply substantially with a standard in the

TICS; and

Develops an alternate standard that will achieve at least the same level of

control for the standard that it seeks to replace.

For each standard for which the gaming operation seeks an alternate, the gaming

operation shall submit to TGA a detailed report which shall include the following

information:

An explanation of why the gaming operation is unable to comply

substantially with the standard;

A description of the proposed alternate standards; and

An explanation of how the proposed alternate standard achieves at least

the same level of control as the standard it is to replace.

TGA may test the adequacy of the alternate standards.

TGA may approve an alternate standard from those required if it has determined

that the alternate standard will achieve a level of security and integrity sufficient

to accomplish the purpose of the standard it is to replace. A gaming operation

may implement an alternate standard upon approval by TGA.

For each applicable enumerated standard for which TGA approves an alternate

standard, it must submit to the Chair of NIGC within 30 days a detailed report

and to the WSGC, which must include the following:

An explanation of how the alternate standard achieves a level of security

and integrity sufficient to accomplish the purpose of the standard it is to

replace; and

The alternate standard as approved and the record on which it is based.

Chair of NIGC review

Under IGRA there are circumstances in which the NIGC Chair may be required to approve certain CTGC

or ilani regulations, these may include: the process to license key employees and facility licenses as

defined under IGRA and NIGC; Tribal Gaming Ordinances; Management contracts; Net Gaming

Revenues; Environmental, Public Health and Safety.

The Chair may approve or object to an alternate standard approved by

TGA.

If the Chair approves the alternate standard, the TGO may continue to use

it as authorized by the TGA.

If the Chair objects, the TGO may no longer use the alternate standard

and must follow the relevant internal controls set forth in the TICS.

Any objection by the Chair must be in writing and provide reasons that the

alternate standard, as approved by the TGA, does not provide a level of

security or integrity sufficient to accomplish the purpose of the standard

it is to replace.

If the Chair fails to approve or object in writing within 60 days after the

date of receipt of a complete submission, the alternate standard is

considered approved by the Chair. The Chair may, upon notification to the

TGA, extend this deadline an additional 60 days.

WSGC review

3.3.

TGA shall notify the WSGC of any intent to revise Class III standards or of

any other regulations issued thereafter and shall request the concurrence

of the WSGC for such revisions. WSGC and TGA shall agree upon the

alternative standards according to the provisions of the TSC Section

IX.A(3)

Variances

Where referenced throughout the TICS, TGO must set a reasonable threshold,

approved by TGA, for when a variance must be reviewed to determine the cause,

and the results of the review must be documented and maintained.

If TGA determines there is a pattern or excessive number of variances which do

not meet the established threshold, TGA may request, and the TGO must

comply, with an adjusted threshold.

3.4.

3.5.

3.6.

Certified Public Accountant (CPA) MICS 543.23

The Certified Public Accountant (CPA) shall perform an independent assessment

to verify whether the TGO’s SICS is in substantial compliance with the TICS by

comparing the documents.

The CPA shall also perform an independent assessment to verify whether the TGO

has implemented and is in substantial compliance with its SICS. These

procedures may be performed in conjunction with the annual audit.

The CPA shall prepare a report of the material weakness in accounting and

system of internal controls for the Tribe and management.

Tribal Gaming Operation shall submit two copies of the CPA’s agreed-upon

procedures report of TGO’s compliance to NIGC within 120 days of TGO’s fiscal

year end in conjunction with the submission of the annual financial audit report.

If the CPA determines that the internal audit procedures performed during the

fiscal year have been properly completed, the CPA may rely on the work of the

internal audit for the completion of the MICS checklists as they relate to the

standards in A and B above with agreement of the Tribal Gaming Agency.

Records, Documents and Retention

The TGO shall keep permanent books of account or records, including inventory

records of gaming supplies, sufficient to establish the amount of gross and net

revenue, deductions and expenses, receipts and disbursements, and other

information required in any financial statement, report, and/or other accounting

records prepared pursuant to these standards. TSC App.A:4(1); App. A:4(4)

These books or records shall be kept at all times and made readily available upon

request for inspection by the authorized representatives of TGA.

Except as otherwise specified in these standards, all required records, reports,

and documents shall be retained for a period of at least five (5) years in a manner

that assures reasonable accessibility. MICS 542.19(k)

Access logs and authorization lists shall be retained for a period of at least two

(2) years in a manner that assures reasonable accessibility. TSC App.A:4(5)

Established Procedures

TGO shall submit initially, and upon each subsequent update, for review,

discussion, and approval, all procedures established pursuant to the standards of

the TICS.

Any requirement for the establishment of procedures pursuant to the standards

of TICS must be submitted to TGA no later than 30-days following the effective

date or thereafter within 20-days of TGA request. Effective dates for updates

shall be upon approval of TGA unless otherwise specified by TGA.

3.7.

Computer Applications

For any computer applications utilized, alternate documentation and/or

procedures that provide at least the level of control established by the standards

of this part, as approved in writing by TGA will be acceptable. MICS 542.12(a);

542.13(b); 542.14(a); 542.41(a)

For Class III gaming, in addition to TGA’s approval, for any computer application

utilized, alternate documentation and/or procedures that provide at least the

level of control established by the Tribal-State Compact need concurrence with

the WSGC. TSC App. A :17(9)

Chapter 4

4.1.

4.2.

Supervision

Supervision must be provided as required for bingo operations by an agent(s)

with authority greater than those being supervised. (MICS 543.8(a))

Key management personnel shall be on the premises at which the bingo game is

licensed for operation, during all hours of its operation. Such personnel shall be

of a position of shift-manager or higher and hold a current and valid license from

the TGA. Such hours of operation shall include at a minimum any time during

which the premises are open to the public for entrance and occupation.

Bingo Card Sales MICS 543.8(c)(4)(i-v)

4.3.

Bingo Minimum Internal Control Standards

In order to adequately record, track and reconcile sales of bingo cards, the

following information must be documented from the server (this is not required

if the system does not track the information, but system limitation(s) must be

noted):

Date;

Time;

Number of bingo cards sold;

Dollar amount of bingo card sales; and

Amount in, amount out and other associated meter information.

Draw MICS 543.8(d)(2-4)(i-ii)

Where the selection is made through an electronic aid, certification in

accordance with 25 CFR 547.14 is acceptable for verifying the randomness of the

draw and satisfies the requirements of paragraph (d)(1) of this section.

Controls must be established and procedures implemented to provide a method

of recall of the draw, which includes the order and identity of the objects drawn,

for dispute resolution purposes.

Verification and display of draw. Controls must be established and procedures

implemented to ensure that:

The identity of each object drawn is accurately recorded and transmitted

to the participants. The procedures must identify the method used to

ensure the identity of each object drawn.

For all games offering a prize payout of $1,200 or more, as the objects

are drawn, the identity of the objects are immediately recorded and

maintained for a minimum of 24 hours.

4.4.

Prize Payout

Controls must be established and procedures implemented for cash or cash

equivalents that address the following: (MICS 543.8(e)(1))

Identification of the agent authorized (by position) to make a payout;

Predetermined payout authorization levels (by position); and

Documentation procedures ensuring separate control of the cash

accountability functions.

Verification of validity. (MICS 543.8(e)(2))

Controls must be established and procedures implemented to verify that

the following is valid for the game in play prior to payment of a winning

prize:

Winning card(s);

Objects drawn; and

The previously designated arrangement of numbers or

designations on such cards.

At least two agents must verify that the card, objects drawn, and

previously designated arrangement were valid for the game in play.

Where an automated verification method is available, verification by such

method is acceptable.

Validation. (MICS 543.8(e)(3))

For manual payouts, at least two agents must determine the validity of

the claim prior to the payment of a prize. The system may serve as one of

the validators.

For automated payouts, the system may serve as the sole validator of the

claim.

Verification. (MICS 543.8(e)(4))

For manual payouts, at least two agents must verify that the winning

pattern has been achieved on the winning card prior to the payment of a

prize. The system may serve as one of the verifiers.

For automated payouts, the system may serve as the sole verifier that the

pattern has been achieved on the winning card.

Authorization and signatures. (MICS 543.8(e)(5))

At least two agents must authorize, sign, and witness all manual prize

payouts above $1,200, or a lower threshold as authorized by

management and approved by the TGA.

Manual prize payouts above the following threshold (or a lower

threshold, as authorized by management and approved by TGA) must

require one of the two signatures and verifications to be a supervisory or

management employee independent of the operation of Class II Gaming

System bingo:

4.5.

$5,000 for a Tier A facility;

$10,000 at a Tier B facility;

$20,000 for a Tier C facility; or

$50,000 for a Tier C facility with over $100,000,000 in gross

gaming revenues

The predetermined thresholds, whether set at the TICS level or lower,

must be authorized by management, approved by TGA, documented, and

maintained.

A Class II gaming system may substitute for one authorization/signature

verifying, validating or authorizing a winning card, but may not substitute

for a supervisory or management authorization/signature.

Payout records, including manual payout records, must include the following

information: (MICS 543.8(e)(6))

Date and time;

Amount of the payout (alpha & numeric for player interface payouts);

and

Bingo card identifier or player interface identifier.

Manual payout records must also include the following:

Game name or number;

Description of pattern covered, such as cover-all or four corners;

Signature of all, but not less than two, agents involved in the

transaction;

For override transactions, verification by a supervisory or

management agent independent of the transaction; and

Any other information necessary to substantiate the payout.

Cash and Cash Equivalent Controls MICS 543.8(f)

Cash or cash equivalents exchanged between two persons must be counted

independently by at least two agents and reconciled to the recorded amounts at

the end of each shift or session. Unexplained variances must be documented and

maintained. Unverified transfers of cash or cash equivalents are prohibited.

Procedures must be implemented to control cash or cash equivalents based on

the amount of the transaction. These procedures must include documentation

by shift, session, or other relevant time period of the following:

Inventory, including any increases or decreases;

4.6.

Transfers;

Exchanges, including acknowledging signatures or initials; and

Resulting variances.

Any change to control of accountability, exchange, or transfer requires that the

cash or cash equivalents be counted and recorded independently by at least two

agents and reconciled to the recorded amount.

Technologic Aids to the Play of Bingo MICS 543.8(g)

Controls must be established, and procedures implemented to safeguard the

integrity of technologic aids to the play of bingo during installations, operations,

modifications, removal and retirements. Such procedures must include the

following:

Shipping and receiving

A communication procedure must be established between the

supplier, the gaming operation, and TGA to properly control the

shipping and receiving of all software and hardware components.

Such procedures must include:

(1)

(2)

(3)

Notification of pending shipments must be provided to TGA by

the gaming operation;

Certification in accordance with 25 CFR part 547;

Notification from the supplier to TGA, or the gaming operation

as approved by TGA, of the shipping date and expected date of

delivery. The shipping notification must include:

(i) Name and address of the supplier;

(ii) Description of shipment;

(iii) For player interfaces: a serial number;

(iv) For software: software version and description of

software;

(v) Method of shipment; and

(vi) Expected date of delivery.

Procedures must be implemented for the exchange of the gaming

system components for maintenance and replacement.

Gaming system components must be shipped in a secure manner

to deter unauthorized access.

TGA, or its designee, must receive all the gaming system

components and game play software packages, and verify the

contents against the shipping notification.

Access credential control methods.

Controls must be established to restrict access to the gaming

system components.

Recordkeeping and audit processes.

The gaming operation must maintain the following records, as

applicable, related to installed game servers and player interfaces:

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

Date placed into service;

Date made available for play;

Supplier;

Software version;

Serial number;

Game title;

Asset and/or location number;

Seal number; and

Initial meter reading.

Procedures must be implemented for auditing such records in

accordance with §543.23, Audit and Accounting.

System software signature verification.

Procedures must be implemented for system software

verifications. These procedures must include comparing

signatures generated by the verification programs required by 25

CFR 547.8, to the signatures provided in the independent test

laboratory letter for that software version.

An agent independent of operation must perform system

software signature verification(s) to verify that only approved

software is installed.

Procedures must be implemented for investigating and resolving

any software verification variances.

Internal audits must be conducted. Such audits must be

documented.

Installation testing.

Testing must be completed during the installation process to

verify that the player interface has been properly installed. This

must include testing of the following, as applicable:

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

Communication with the gaming system;

Communication with the accounting system;

Communication with the player tracking system;

Currency and vouchers to bill acceptor;

Voucher printing;

Meter incrimination;

Pay table, for verification;

Player interface denomination, for verification;

All buttons, to ensure that all are operational and programmed

(10)

(11)

4.7.

appropriately;

System components, to ensure that they are safely installed at

location; and

Locks, to ensure that they are secure and functioning.

Display of rules and necessary disclaimers.

The operation must ensure that all game rules and disclaimers are

displayed at all times or made readily available to the player upon

request,

TGA must verify that all game rules and disclaimers are displayed

at all times or made readily available to the player upon request,

as required by 25 CFR part 547

TGA approval of all technologic aids before they are offered for play.

All Class II gaming equipment must comply with 25 CFR part 547,

Minimum Technical Standards for Gaming Equipment Used with the Play

of Class II Games; and

Dispute resolution.

Operations MICS 543.8(h)

Malfunctions - Procedures must be implemented to investigate, document and

resolve malfunctions. Such procedures must address the following:

Determination of the event causing the malfunction;

Review of relevant records, game recall, reports, logs, surveillance

records;

Repair or replacement of the gaming component;

Verification of the integrity of the gaming component before restoring it

to operation.

Removal, retirement and/or destruction. Procedures must be implemented to

retire or remove any or all associated components of a gaming system from

operation. Procedures must include the following:

For player interfaces and components that accept cash or cash

equivalents:

Coordinate with the drop team to perform a final drop;

Collect final accounting information such as meter readings, drop

and payouts;

Remove and/or secure any or all associated equipment such as

locks, card reader, or ticket printer from the retired or removed

component; and

Document removal, retirement, and/or destruction.

For removal of software components:

4.8.

Purge and/or return the software to the license holder; and

Document the removal.

For other related equipment such as blowers, cards, interface cards:

Remove and/or secure equipment; and

Document the removal or securing of equipment.

For all components:

Verify that unique identifiers, and descriptions of removed/retired

components are recorded as part of the retirement

documentation; and

Coordinate with the accounting department to properly retire the

component in the system records.

Where TGA authorizes destruction of any gaming system components,

procedures must be developed to destroy such components. Such

procedures must include the following:

Methods of destruction;

Witness or surveillance of destruction;

Documentation of all components destroyed; and

Signatures of agent(s) destroying components attesting to

destruction

Vouchers MICS 543.8(i)

Controls must be established and procedures implement to:

Verify the authenticity of each voucher redeemed.

If the voucher is valid, verify that the patron is paid the appropriate

amount.

Document the payment of a claim on a voucher that is not physically

available or a voucher that cannot be validated such as a mutilated,

expired, lost, or stolen voucher.

Retain payment documentation for reconciliation purposes.

For manual payment of a voucher of $500 or more, require a supervisory

employee to verify the validity of the voucher prior to payment.

4.9.

Vouchers paid during a period while the voucher system is temporarily out of

operation must be marked “paid” by the cashier.

Vouchers redeemed while the voucher system was temporarily out of operation

must be validated as expeditiously as possible upon restored operation of the

voucher system.

Paid vouchers must be maintained in the cashier's accountability for

reconciliation purposes.

Unredeemed vouchers can only be voided in the voucher system by supervisory

employees. The accounting department will maintain the voided voucher, if

available.

Variance MICS 543.8(l)

The operation must establish, as approved by TGA, the threshold level of at least

+/- 3%, at which a variance, including deviations from the mathematical

expectations required in this section, will be reviewed to determine the cause.

Any such review must be documented.

Fairness. No gaming system may cheat or mislead users. All prizes

advertised must be available to win during the game. A test laboratory

must calculate and/or verify the mathematical expectations of game play,

where applicable, in accordance with the manufacturer stated

submission. The results must be included in the test laboratory's report

to TGA.

Chapter 5

5.1.

Supervision

5.2.

5.3.

5.4.

CARD GAMES

Supervision must be provided as required during the card room operations by an

agent(s) with authoritygreater than those being supervised.

A supervisor may function as a dealer without any other supervision if

disputes are resolved, and exchanges and transfers are authorized by

other supervisory agents.

A dealer may function as a supervisor if not dealing the game.

Exchanges or Transfers

Exchanges between table banks and the main card room bank (or cage, if a main

card room bank is not used) must be authorized by a supervisor. All exchanges

must be evidenced by the use of a lammer unless the exchange of chips, tokens,

and/or cash takes place at the table. If table banks are maintained at an imprest

level and runners are used for the exchanges at the table, no supervisory

authorization is required.

Exchanges from the main card room bank (or cage, if a main card room bank is

not used) to the table banks must be verified by the card room dealer and the

runner.

Transfers between the main card room bank and the cage must be properly

authorized and documented. Documentation must be retained for at least 24

hours.

Playing Cards

New and used playing cards must be maintained in a secure location, with

appropriate surveillance coverage, and accessible only to authorized agents.

Used playing cards that are not to be re-used must be properly cancelled and

removed from service to prevent re-use. The removal and cancellation

procedure requires TGA review and approval.

Playing cards associated with an investigation must be retained intact and

outside of the established removal and cancellation procedure.

Shill Funds

Issuance of shill funds must be recorded and have the written approval of the

supervisor.

Returned shill funds must be recorded and verified by a supervisor.

5.5.

Reconciliation of Card Room Bank

5.6.

The replenishment of shill funds must be documented.

Two agents—one of whom must be a supervisory agent—must independently

count the table inventory at the opening and closing of the table and record the

following information:

Date;

Shift;

Table number;

Amount by denomination;

Amount in total; and

Signatures of both agents.

Posted Rules

The rules must be displayed or available for patron review at the gaming

operation, including rules governing contests, prize payouts, fees, the rake

collected, and the placing of antes.

5.7.

Prohibitions on side betting between and against player and against the

house.

Promotional Progressive Pots and Pools

All funds contributed by players into the pools must be returned when won in

accordance with posted rules, and no commission or administrative fee may be

withheld.

The payout may be in the form of personal property, such as a car.

A combination of a promotion and progressive pool may be offered.

The conditions for participating in current card game promotional progressive

pots and/or pools must be prominently displayed or available for patron review

at the gaming operation.

Individual payouts for card game promotional progressive pots and/or pools that

are $600 or more must be documented at the time of the payout to include the

following:

Patron's name;

Date of payout;

Dollar amount of payout and/or nature and dollar value of any non-cash

payout;

The signature of the agent completing the transaction attesting to the

disbursement of the payout; and

Name of contest/tournament.

If the cash (or cash equivalent) payout for the card game promotional

progressive pot and/or pool is less than $600, documentation must be created to

support accountability of the bank from which the payout was made.

Rules governing current promotional pools must be conspicuously posted in the

card room and/or available in writing for patron review. The rules must

designate:

The amount of funds to be contributed from each pot;

What type of hand it takes to win the pool;

How the promotional funds will be paid out;

How/when the contributed funds are added to the pools; and

Amount/percentage of funds allocated to primary and secondary pools, if

applicable.

Promotional pool contributions must not be placed in or near the rake circle, in

the drop box, or commingled with gaming revenue from card games or any other

gambling game.

The amount of the pools must be conspicuously displayed in the card room.

At least once each day that the game is offered, the posted pool amount must be

updated to reflect the current pool amount.

At least once each day that the game is offered, agents independent of the card

room must reconcile the increases to the posted pool amount to the cash

previously counted or received by the cage.

All decreases to the pool must be properly documented, including a reason for

the decrease.

Promotional funds removed from the card game must be placed in a locked

container.

Agents authorized to transport the locked container are precluded from

having access to the contents keys.

The contents key must be maintained by a department independent of

the card room.

At least once a day, the locked container must be removed by two

agents, one of whom is independent of the card games department, and

transported directly to the cage or other secure room to be counted,

recorded, and verified, prior to accepting the funds into cage

accountability.

5.8.

5.9.

Accepting Cash at Gaming Stations

The cash shall be spread on the top of the gaming station by the dealer or

croupier, accepting it in full view of the patron who presented it and the

supervisor specifically assigned to such gaming station.

The amount of cash shall be announced by the dealer or croupier accepting it in

a tone of voice calculated to be heard by the patron who presented the cash and

the supervisor specifically assigned to such gaming station. All cash changes of

$100 or over shall be verified by the supervisor.

Immediately after an equivalent amount of gaming chips has been given to the

patron, the cash shall be taken from the top of the gaming station and placed by

the dealer or croupier into the drop box attached to the gaming station.

Acceptance of Gratuities from Patrons

No tribal gaming operation employee directly concerned with management,

accounting, security and surveillance shall solicit or accept any tip or gratuity

from any player or patron.

The tribal gaming operation shall establish a procedure for accounting for all tips

received by other gaming employees.

Upon receipts from a patron of a tip, a dealer assigned to a gaming station shall

tap the table or wheel and extend his or her arm to show the supervisor that he

has received a tip and immediately deposit such tip in the tip box. Tips received

shall be retained by employees or pooled among employees in such a manner as

determined by the TGO.

Chapter 6

6.1.

Supervision MICS 543.12(a)

6.2.

6.4.

Supervision must be provided as required for gaming promotions and player

tracking by an agent(s) with authority greater than those being supervised.

Gaming promotions 543.12(b)

6.3.

GAMING PROMOTIONS & PLAYER TRACKING

The rules of the gaming promotion must be displayed or made readily available

to patron upon request. Gaming promotions rules require TGA approval and

must include the following:

The rules of play;

The nature and value of the associated prize(s) or cash award(s);

Any restrictions or limitations on participant eligibility;

The date(s), time(s), and location(s) for the associated promotional

activity or activities;

Any other restrictions or limitations, including any related to the claim of

prizes or cash awards;

The announcement date(s), time(s), and location(s) for the winning entry

or entries; and

Rules governing promotions offered across multiple gaming operations,

third party sponsored promotions, and joint promotions involving third

parties.

Player Tracking Systems and Gaming Promotions 543.12(c)

Changes to the player tracking systems, promotion and external bonusing

system parameters, which control features such as the awarding of bonuses, the

issuance of cashable credits, non-cashable credits for gaming, coupons and

vouchers, must be performed under the authority of supervisory agents,

independent of the department initiating the change. Alternatively, the changes

may be performed by supervisory agents of the department initiating the change

with notification of TGA, if sufficient documentation is generated and the

propriety of the changes are verified by supervisory agents independent of the

department initiating the change.

All other changes to the player tracking system must be appropriately

documented.

Player Tracking System Controls MICS 543.12(c)(2)

The player tracking system shall be secured so as to prevent unauthorized access

(e.g., changing passwords at least quarterly and physical access to computer

hardware, etc.).

The addition of points to members’ accounts other than through actual gaming

play shall be sufficiently documented (including substantiation of reasons for

increases). Each request shall be in writing by the department determining an

adjustment is necessary. The written request shall be forwarded to a designated

person or group within accounting, as designated by the operation, who will

review and (if appropriate) authorize the adjustment. Authorized point

adjustments shall then be forwarded to Marketing or Player Services staff as

designated by the operation. This employee may not have the ability to either

create player’s club accounts or issue momentum cards.

Employees who redeem points for members shall not have access to lost cards.

Chapter 7

7.1.

Supervision

7.2.

Pit supervisory personnel (with authority equal to or greater than those being

supervised) shall provide supervision of all table games.

Table Inventory Requirements and Procedures TSC App. A:16(1-4)

7.3.

TABLE GAMES

Station inventory slips shall be a pre-numbered, three-part form, “Opener,”

“Closer,” and triplicate, which are maintained and controlled by security. The

Gaming Facility supervisor shall record the following:

The date and identification of the shift ended;

The game and station number;

The value of each denomination of gaming chips and coins, and total.

Signatures shall be of either the Dealer and the Gaming Facility

supervisor assigned to the incoming and outgoing shifts or the Gaming

Facility supervisor assigned to the gaming station at the time of a Drop

Box shift change and another table games employee.

Each station inventory and the Opener shall be stored while not in use in a

separate locked, clear container which shall be clearly marked on the outside

with the game and the gaming station number to which it corresponds. The

information on the Opener shall be visible from the outside of the container. All

containers shall be stored either in the cashier's cage or secured to the gaming

station while not in use.

The keys to the locked containers containing the station inventories shall be

maintained and controlled by the Gaming Facility department in a secure place

and will not be accessible to any cashier's cage or security personnel.

Gaming chips or coins cannot be added to or removed from station inventory

during the gaming day except:

In exchange for cash;

In payment of winning wagers and collection of losing wagers made at

such gaming station;

In exchange for gaming chips received from a patron having an equal

aggregate face value; and

In conformity with the fill and credit procedures described in these

standards.

Procedures for Opening Stations for Gaming TSC App. A:16(5)

Gaming stations will be opened for gaming activity as follows:

The inventory container shall be unlocked in the presence of the Gaming

Facility supervisor.

7.4.

7.5.

A Dealer shall count the contents of the container in the presence of the

Gaming Facility supervisor and shall verify the count to the Opener

removed from the container.

The Dealer and the Gaming Facility supervisor will sign the Opener.

Any discrepancy between the table inventory and the Opener shall be

immediately reported to at least the Gaming Facility shift manager, the

security department, and the Tribal Gaming Agency Inspector. A

Notification of Error (NOE) or security report shall be completed in

conformity with agreed upon internal controls. In the event a security

report is written; a copy must be forwarded to accounting for

reconciliation purposes.

After the count of the contents of the container and the signing of the

Opener, it shall be immediately deposited in the Drop Box attached to

the gaming station by the Dealer.

Procedures for Closing Gaming Stations TSC App. A:16(6-7)

When gaming activity at a gaming station is concluded, the gaming chips and

coins shall be counted by the Dealer assigned to the gaming station and

observed by a table games supervisor.

The gaming chips and coins counted shall be recorded on a station inventory slip

by the table games supervisor

The Dealer and the table games supervisor, who observed the Dealer count, will

sign the station inventory slip.

Upon meeting the signature requirements, the Closer shall be deposited in a

Drop Box attached to the gaming station immediately prior to the closing of the

station.

The triplicate copy of the station inventory slip shall be forwarded to the

cashier’s cage by a Security Department Member.

The Opener and the gaming chips remaining at the station shall be stored as

outlined in 7.2B.

Fill and Credit General Standards MICS 542.12(c)(1-4)

Fill slips and credit slips shall be in at least triplicate form, in a continuous

numerical series, and pre-numbered and concurrently numbered in a form

utilizing the alphabet and only in one series at a time. The alphabet need not be

used if the numerical series is not repeated during the business year.

Unissued and issued fill/credit slips shall be safeguarded and adequate

procedures shall be employed in the distribution, use, and control of unissued

and issued fill/credit slips. Personnel from the cashier or pit departments shall

have no access to the secured copies of the fill/credit slips.

7.6.

When a fill/credit slip is voided, the cashier shall clearly mark “void” across the

face of the original and first copy. The cashier and one other person independent

of the transactions shall sign both the original and first copy, and shall submit

them to the accounting department for retention and accountability.

Fill transactions shall be authorized by pit supervisory personnel before the

issuance of fill slips and transfer of chips, tokens, or cash equivalents. The fill

request shall be communicated to the cage where the fill slip is prepared.

Table credit transactions shall be authorized by a pit supervisor before the

issuance of credit slips and transfer of chips, tokens, or other cash equivalent.

The credit request shall be communicated to the cage where the credit slip is

prepared. MICS 542.12(c)(12)

Fill Slip Standards

When table fills are transacted, a two-part request for fill shall be prepared by

the pit supervisor for transferring chips, or monetary equivalents from the cage

to the pit. TSC App. A:17(1)(a) and (c); MICS 542.12(c)(4)

The duplicate of the fill request form shall be retained in the pit to check the fill

slip for proper entries and to document the total amount of chips and monetary

equivalents to be added to the table inventory. TSC App.A:17(1)(c)(vi)

The original of the fill request shall be communicated to the cage where the fill

slip is prepared. MICS 542.12(c)(4)

At least three parts of each fill slip shall be utilized as follows: MICS 542.12(c)(5)

Two parts shall be transported to the pit with the fill and, after the

appropriate signatures are obtained, one part shall be deposited in the

table drop box with the fill request duplicate;

One part shall be retained in the cage for reconciliation of cashier bank

once signed by all participants and returned to the Cage by security; and

One part shall be retained intact by the locked machine in a continuous

unbroken form. PROVIDED, for an automated system, the restricted copy

may be retained within the automated system.

The part of the fill slip that is placed in the drop box shall be of a different color

for fills than for credits, unless the type of transaction is clearly distinguishable in

another manner (the checking of a box on the form shall not be a clearly

distinguishable indicator). MICS 542.12(c)(6)

7.7.

The game, table number, shift, and amount of fill by denomination and in total

shall be noted on all copies of the fill slip. The correct date and time shall be

indicated on at least two copies. 542.12(c)(7)

All fills shall be carried from the cashier’s cage by a Security Department

member. 542.12(c)(8)

The fill slip shall be signed by at least the following individuals (as an indication

that each has counted the amount of the fill and the amount agrees with the fill

slip): MICS 542.12(c)(9)

Cashier who prepared the fill slip and issued the chips, tokens, or

monetary equivalent;

Security Department member who carried the chips, tokens, or monetary

equivalents from the cage to the pit;

Dealer who received the chips, tokens, or monetary equivalents at the

gaming table; and

Gaming Facility supervisor who supervised the fill transaction.

Fills shall be either broken down or verified by the dealer in public view before

the dealer places the fill in the table tray. MICS 542.12(c)(10)

All fill slips requesting chips or money shall be prepared at the time a fill is made.

A copy of the fill slip shall then be deposited with the fill request duplicate into

the drop box on the table by the dealer, where it shall appear in the count room

with the cash receipts for the shift. MICS 542.12(c)(12); TSC App. A:17(6)(c)

Credit Slip Standards

When table credits are transacted, a two-part request for credit shall be

prepared by the pit supervisor for transferring chips, tokens, or monetary

equivalents from the pit to the cashier area or other secure area of

accountability. TSC App. A:17(1)(a) and (c); MICS 542.12(c)(12)

The duplicate copy of a request for credit shall be retained in the pit to check the

credit slip for proper entries and to document the total amount of chips, tokens,

and monetary equivalents removed from the table. TSC App. A:17(1)(c)(vi)

The original of the credit request shall be communicated to the cage where the

credit slip is prepared. MICS 542.12(c)(12)

At least three parts of each credit slip shall be utilized as follows: MICS 542.12(c)(13)

One part shall be retained in the cage for reconciliation of the cashier

bank once signed by all participants and returned to the Cage with the

credit;

Two parts shall be transported to the pit by the Security Department

member who transports chips, tokens, or monetary equivalents from the

pit to the cage, and after the appropriate signatures are obtained, one

part shall be deposited in the table drop box with the credit request

duplicate;

One part shall be retained by the locked machine intact in a continuous

unbroken form. PROVIDED, for an automated system, the restricted copy

may be retained within the automated system.

The game, table number, shift, and the amount of credit by denomination and in

total shall be noted on all copies of the credit slip. The correct date and time

shall be indicated on at least two copies. MICS 542.12(c)(14)

Chips, tokens, and/or monetary equivalents shall be removed from the table tray

by the dealer and shall be broken down or verified by the dealer in public view

prior to placing them in racks for transfer to the cage. MICS 542.12(c)(15)

All chips, tokens, and monetary equivalents removed from the tables shall be

carried to the cashier’s cage by a Security Department member. MICS 542.12(c)(16);

TSC App. A:17(7)(a)

The credit slip shall be signed by at least the following individuals (as an

indication that each has counted the items transferred): MICS 542.12(c)(17); TSC App.

A:17(5)

Cashier who received the items transferred from the pit and prepared

the credit slip;

Security Department member who carried the items transferred from the

pit to the cage and returned to the pit with the credit slip;

Dealer who had custody of the items prior to transfer to the cage; and

Gaming facility supervisor who supervised the credit transaction.

The credit slip shall be inserted with the credit request duplicate in the drop box

by the dealer. MICS 542.12(c)(18)

Chips, tokens, or other monetary equivalents shall be deposited on or removed

from gaming tables only when accompanied by the appropriate fill/credit slip.

MICS 542.12(c)(19)

7.8.

Table Games Computer Generated Documentation Standards

A computerized system may replace the manual fill or Credit process. TSC App.

A:17(9)

The system is approved by the Tribal Gaming Agency prior to use after

confirming the system meets the standards of control set out in the

manual system

The system provides for adequate separation of duties within the system

through passwords or other security features

If at any time the computerized system fails, the manual process will be

followed until the computerized system returns to full capabilities

The computer system shall be capable of generating adequate documentation of

all information recorded on the source documents and transaction detail (e.g.,

fill/credit slips, etc.). MICS 542.12(e)(1)

This documentation shall be restricted to authorized personnel. MICS 542.12(e)(2)

The documentation shall include, at a minimum, system exception information

(e.g., appropriate system parameter information, corrections, voids, etc.). MICS

542.12(e)(3)(i)

7.9.

The electronic system must include a personnel access listing, which includes, at

a minimum: MICS 542.12(e)(3)(ii)

Employee name;

Employee identification number; and

Listing of functions employees can perform or equivalent means of

identifying the same.

Playing Cards and Dice Standards

Playing cards and dice not yet issued to the pit shall be physically controlled by

the Security Department and maintained in a secure location to prevent

unauthorized access and reduce the possibility of tampering. MICS 542.12(f)(1); TSC

App. A:6(3)(a)(iv)

Used cards and dice, when removed from play, shall be “marked,” “scored,” or

“cancelled” to prevent unauthorized access and reduce the possibility of

tampering. MICS 542.12(f)(3)

The Security Department shall physically control and maintain used playing cards

and dice in a secure location until destroyed in a timely manner not to exceed

seven days. However, this standard shall not apply where playing cards or dice

are retained for an investigation. MICS 542.12(f)(3)

Card control logs shall be maintained that document when cards and dice are

received on site, distributed to and returned from tables, or removed from play

by the gaming operation, and destroyed. MICS 542.12(f)(4)

If a gaming operation uses plastic cards (not plastic-coated cards), the cards may

be used for up to three (3) months if the plastic cards are routinely inspected,

and washed or cleaned in a manner and time frame approved by TGA. MICS

542.12(g)

7.10. Analysis of Table Game Performance Standards MICS 542.12(i); TSC App. A:4(4)(a)

Records shall be maintained, by day and shift, indicating any single-deck

blackjack games that were dealt for an entire shift.

Records reflecting hold percentage by table and type of game shall be

maintained by shift, by day, cumulative month-to-date, and cumulative year-todate.

This information shall be presented to and reviewed by management

independent of the pit department on at least a monthly basis.

Such management shall investigate any unusual fluctuations in hold

percentage with pit supervisory personnel.

The results of such investigations shall be documented, maintained for

inspection, and provided to TGA upon request.

Chapter 8

8.1.

System Overview

8.2.

ELECTRONIC GAMING SYSTEMS

The Electronic Gaming System (EGS) consists of both Class II and Class III gaming

systems. Gaming Machine also consists of both Class II and Class III for the

purposes of this control. The Tribal Lottery System (TLS) is a class III system with

terminals referred to as Player Terminals. The bingo-based gaming system (BGS)

is Class II with video terminals referred to as Electronic Gaming Machines (EGM)

for the purposes of this control.

EGS Jackpot Standards

Jackpot Payouts and Accumulated Credit Payouts Standards for EGM/Player

Terminal for jackpot payouts, documentation shall include the following

information:

Date and time; (MICS 542.13(d)(i))

Machine number; (MICS 542.13(d)(ii))

Dollar amount of cash payout (both alpha and numeric) or description of

personal property awarded, including fair market value. Alpha is optional

if another unalterable method is used for evidencing the amount of the

payout; (MICS 542.13(d)(iii))

Game outcome (including reel symbols, card values, suits, etc.) for

jackpot payouts. Game outcome is not required if a computerized

jackpot/fill system is used; (MICS 542.13(d)(iv))

Signatures of at least two employees verifying and witnessing the payout;

Preprinted or concurrently printed sequential number. (MICS 542.13(d)(v))

(MICS 542.13(d)(vi))

Surveillance is notified prior to initiation of payout procedures for jackpot

awards equal to or greater than $10,000

Jackpot payouts over $25,000 shall require the signature and verification of a

supervisory or management employee independent of the Electronic Gaming

Department (in addition to the two signatures required in paragraph 8.2.A.5 of

this section). Alternatively, if an on-line accounting system is utilized, only two

signatures are required: one employee and one supervisory or management

employee independent of the Electronic Gaming Department. This

predetermined amount shall be authorized by management (as approved by the

Tribal gaming regulatory authority), documented, and maintained. (MICS

542.(d)(vi)(A)

Computerized jackpot systems shall be restricted so as to prevent unauthorized

access and fraudulent payouts by one individual. (MICS 542.13(d)(3))

8.3.

EGS Funds Standards

8.4.

Payout forms shall be controlled and routed in a manner that precludes any one

individual from producing a fraudulent payout and misappropriating the funds

by forging signatures or by altering the amount paid out. (MICS 542.13(d)(4))

The Gaming Machine cage and change banks, which are active during the shift,

shall be counted down and reconciled each shift utilizing a count sheet that

documents funds by denomination. (MICS 542.13(f)(1))

EGM/Player Terminal Software Media Standards

At least annually, procedures shall be performed to insure the integrity of a

sample of game software media by personnel independent of the gaming

operation or the machines being tested. (MICS 542.13(g)(1))

Game software media control standards.

Procedures shall be developed and implemented for the following:

Removal of game software media, from devices, for verification or signature;

(MICS 542.13(g)(2)(i))

Receipt and destruction of game software media; (MICS 542.13(g)(2)(iv)) and

Securing the game software media, from unrestricted access. (MICS

Records, which document the above game software media procedures,

shall include the following information:

542.13(g)(2)(v))

Date; (MICS 542.13(g)(5)(i))

Machine number (source and destination); (MICS 542.13(g)(5)(ii))

Manufacturer; (MICS 542.13(g)(5)(iii))

Program number; (MICS 542.13(g)(5)(iv))

Personnel involved; (MICS 542.13(g)(5)(v))

Disposition of any permanently removed game software media;

Approved testing lab approval numbers, if available. (MICS

(MICS 542.13(g)(5)(vii))

542.13(g)(5)(ix))

The master game program number, par percentage, and the pay table

shall be verified to the par sheet when initially received from the

manufacturer. (MICS 542.13(g)(3))

EGM/Player Terminals shall have the circuit boards locked and the key(s)

will be controlled by TGA. The lock shall necessitate the presence of an

individual independent of the electronic game department to access the

device game program game software media. (MICS 542.13(g)(4)

8.5.

EGS Player Tracking

8.6.

Game software media, returned to gaming devices shall be labeled with the

program number. Supporting documentation shall include the date, program

number, information identical to that shown on the manufacturer's label, and

initials of the person replacing the game software media. (MICS 542.13(g)(6)

Systems shall be permissible that allow player tracking, maintenance tracking,

and other gaming management or marketing functions. These systems shall not

interfere with, or in any way affect, the outcome of any Tribal Lottery Game or

the cashless accounting system. Systems shall be permissible that allow

progressive prize management with the certification of the Gaming Test

Laboratory and approval of the SGA. (TSC X2 8.3)

EGS Theoretical and Actual Hold Percentage Evaluation Standards

Accurate and current theoretical hold worksheets shall be maintained for each

Gaming Machine. (MICS 542.13(h)(1))

Records shall be maintained for each machine which indicate the date the

machine was placed into service, the date the machine was removed from

operation, the date the machine was placed back into operation, and any

changes in machine numbers and designations. (MICS 542.13(h)(7))

All of the Gaming Machines shall contain functioning meters which shall record

credit-in. (MICS 542.13(h)(8))

All Gaming Machines with bill/ticket acceptors shall contain functioning ticket-in

meters which record the value amounts or number of bills/tickets accepted. (MICS

542.13(h)(9))

GamingGaming Machine in-meter readings shall be recorded at least weekly

immediately prior to or subsequent to a Gaming Machine drop. However, the

time between readings may extend beyond one week in order for a reading to

coincide with the end of an accounting period only if such extension is for no

longer than six days. (MICS 542.13(h)(10))

The employee who records the in-meter reading shall either be independent of

the count team or shall be assigned on a rotating basis, unless the in-meter

readings are randomly verified quarterly for all Gaming Machines and currency

acceptors by someone other than the regular in-meter reader. (MICS 542.13(h)(11))

Upon receipt of the meter reading summary, the accounting department shall

review all meter readings for reasonableness using pre-established parameters.

(MICS 542.13(h)(12))

Prior to final preparation of statistical reports, meter readings that do not appear

reasonable shall be reviewed with Electronic Gaming Department employees,

and exceptions documented, so that meters can be repaired or clerical errors in

the recording of meter readings can be corrected. (MICS 542.13(h)(13))

A report shall be produced at least monthly showing month-to-date, year-todate, and if practicable, life-to-date actual hold percentage computations for

individual machines and a comparison to each machine’s theoretical hold

percentage previously discussed. (MICS 542.13(h)(14))

Each change to a Gaming Machine’s theoretical hold percentage, including

progressive percentage contributions, shall result in that machine being treated

as a new machine in the statistical reports (i.e., not commingling various hold

percentages). (MICS 542.13(h)(15))

If promotional payouts or awards are included on the Gaming Machine statistical

reports, it shall be in a manner that prevents distorting the actual hold

percentages of the affected machines. (MICS 542.13(h)(16))

The statistical reports shall be reviewed by both Electronic Gaming Department

management and management employees independent of the Electronic

Gaming Department on at least a monthly basis. (MICS 542.13(h)(17))

those machines that have experienced at least 100,000 wagering transactions,

Large variances (three percent (3%) recommended) between theoretical hold

and actual hold shall be investigated and resolved by a department independent

of the Electronic Gaming Department with the findings documented and

provided to the TGA upon request in a timely manner. (MICS 542.13(h)(18))

TGA will be notified and follow-up shall be performed for any one machine

having an unresolved variance between actual cash drop and the report

information in excess of an amount that is both more than $25 and at least three

percent (3%) of the actual cash drop. The follow-up performed and results of the

investigation shall be documented and maintained for inspection. (MICS

542.13(m)(5)(7))

Maintenance of the computerized Gaming Machine monitoring system data files

(if applicable) shall be performed by a department independent of the Electronic

Gaming Department. Alternatively, maintenance may be performed by gaming

machine supervisory employees if sufficient documentation is generated and it is

randomly verified on a monthly basis by employees independent of the

Electronic Gaming Department. (MICS 542.13(h)(19))

8.7.

Updates to the computerized Gaming Machine monitoring system (if applicable)

to reflect additions, deletions, or movements of Gaming Machines shall be made

at least weekly prior to in- meter readings. (MICS 542.13(h)(20))

In-house Progressive EGS Standards

A meter that shows the amount of the progressive jackpot shall be conspicuously

displayed at or near the machines to which the jackpot applies. (MICS 542.13(k)(1)) At

least once a month, each gaming operation shall record the amount shown on

each progressive jackpot meter at the gaming operation except for those

jackpots that can be paid directly from the machine; (MICS 542.13(k)(2))

Explanations for meter reading decreases shall be maintained with the

progressive meter reading sheets, and where the payment of a jackpot is the

explanation for a decrease, the gaming operation shall record the jackpot payout

number on the sheet or have the number reasonably available; and (MICS

542.13(k)(3))

8.8.

Each gaming operation shall record the base amount of each progressive jackpot

the gaming operation offers. (MICS 542.13(k)(4))

The TGA shall approve procedures specific to the transfer of progressive

amounts in excess of the base amount to other Gaming Machines. Such

procedures may also include other methods of distribution that accrue to the

benefit of the gaming public via an award or prize. (MICS 542.13(k)(5))

EGM Wide Area Progressive Standards

A meter that shows the amount of the progressive jackpot shall be conspicuously

displayed at or near the machines to which the jackpot applies. (MICS 542.13(l)(1))

As applicable to participating gaming operations, the wide area progressive

Gaming Machine system shall be adequately restricted to prevent unauthorized

access. (MICS 542.13(l)(2))

The TGA shall approve procedures for the wide area progressive system that:

(MICS 542.13(l)(3))

Reconcile meters and jackpot payouts;

Collect/drop Gaming Machine funds;

Verify jackpot, payment, and billing to gaming operations on pro-rata

basis;

System maintenance;

System accuracy; and

System security.

8.9.

EGS Cash-Out Ticket Standards

For EGS machines that accept currency (or tickets) and issue cash-out tickets, the

following standards shall apply:

In addition to the applicable portions of Electronic Game

Accounting/Auditing Procedures Standards, on a quarterly basis, the

gaming operation shall foot all jackpot cash-out tickets and trace totals to

those produced by the system. (MICS 542.13(n)(1)

The customer may request a cash-out ticket from the EGM/Player

Terminal that reflects all remaining credits. The cash-out ticket shall be

printed at the EGM/Player Terminal by an internal document printer.

(MICS 542.13(n)(2)

The customer shall redeem the cash-out ticket at a cashier’s cage or

redemption kiosk. (MICS 542.13(n)(3) Once presented for redemption, the

cashier shall:

Scan the bar code via an optical reader or its equivalent; or (MICS

Input the cash-out ticket validation number into the computer.

542.13(n)(4)(i)

(MICS 542.13(n)(4)(ii)

Alternatively, if operation utilizes a remote computer validation system,

operation as approved by TGA, shall develop alternate standards for the

maximum amount that can be redeemed, which shall not exceed

$2,999.99 per cash-out transaction. (MICS 542.13(n)(3)

The information from the cash-out ticket presented shall be transmitted

to the host computer. The host computer shall verify the authenticity of

the cash-out ticket and communicate directly to the cashier cage

terminal. (MICS 542.13(n)(5)

If valid, the cashier pays the customer the appropriate amount and the

cash-out ticket is electronically noted “paid” in the system. The “paid”

cash-out ticket shall remain in the cashier’s bank for reconciliation

purposes. (MICS 542.13(n)(6)

If invalid, the host computer shall notify the cashier that one of the

following conditions exists: (MICS 542.13(n)(7)

The serial number cannot be found on file (stale date, forgery,

etc.);

The cash-out ticket has already been paid; or

The amount of the cash-out ticket differs from the amount on file.

If invalid, the cashier shall refuse payment to the customer and notify a

supervisor of the invalid condition. The supervisor shall resolve the

dispute. (MICS 542.13(n)(7)

If the host validation system temporarily goes down, cashiers may

redeem cash-out tickets after recording the following: (MICS 542.13(n)(8)

10.

Serial number of the cash-out ticket;

Date and time;

Dollar amount;

Issuing EGM/Player Terminal number;

Mark the ticket as “paid”; and

Ticket shall remain in cashier's bank for reconciliation purposes.

Such cash-out tickets redeemed shall be validated as expeditiously as

possible when the cashless electronic game system is restored. (MICS

542.13(n)(9)

11.

12.

The operation shall develop and implement procedures to control cashout ticket paper which shall include procedures which: (MICS 542.13(n)(10)

Mitigate the risk of counterfeiting of cash-out ticket paper;

Adequately controls the inventory of the cash-out ticket paper;

and

Provide for the destruction of all unused cash-out ticket paper.

If the host validation system is down for more than one hour, the gaming

operation shall promptly notify TGA. (MICS 542.13(n)(11)

8.10. EGS Kiosks

Kiosks shall have reports that properly document all transactions, as well as

dedicated video surveillance, to protect the integrity of the cashless system

used. Cash boxes shall be designed so their contents are protected from

unauthorized access, in accordance with Appendix A drop box and

transportation standards and shall be uniquely labeled for the purpose of audit

and security. (TSC X2 8.4)

8.11. Description of Tribal Lottery System (TLS) General Description (TSC X2 3.1):

The Tribal Lottery System game known as the Electronic Scratch Ticket Game

consists of a finite number of Electronic Scratch Tickets, a certain number of

which, if drawn, entitle a player to prize awards at various levels. The scratch

tickets are designed from a template in conformity with this Appendix and are

created in Game Sets on a Manufacturing Computer from which Scratch Tickets

are randomly selected and placed into Scratch Ticket Subsets. Each Game Set

has a predetermined number of winners and values and is designed so as to

assure players of an at least 75% payback of the amounts paid in the aggregate

for all tickets in the Set. As a Game Set’s tickets are placed into Subsets, the pool

of tickets available from that Game Set for placement into Subsets diminishes,

until each ticket in the Game Set has been placed into a Subset. (TSC X2 3.1.1)

Scratch Ticket Subsets are transmitted to the Central Computer, where they are

stored until dispensed electronically on demand to Player Terminals. Scratch

Tickets are electronically dispensed from the Central Computer in the order

within each Subset in which the tickets were received. Players compete against

each other to draw winning tickets. As Subsets are used they are replaced by

additional Subsets which have been created and delivered to the Central

Computer in the same manner, until the Game Set has been depleted, or pulled

from play, ending that particular game. Different games based on different

Game Sets may be offered simultaneously through the Central Computer. (TSC X2

3.1.2)

A player initiates participation in an Electronic Scratch Ticket game at a Player

Terminal, using Game Play Credits purchased on the Player Terminal through the

insertion of cash, or through the Cashless Transaction System. The monitor

displays one or more of the Electronic Scratch Ticket games that are offered by

the system, as well as other information such as graphics, game play and

outcome information, and entertainment effects, subject to the limitations in

Sections 5.2.2 and 5.2.3. The player may choose a particular game and reveal

the outcome, by touching the screen, pressing a button once or performing

some other form of interaction with the Player Terminal. (TSC X2 3.1.3)

Following or as part of the player’s selection of a game or games, the

player uses Game Play Credits displayed on the Player Terminal to

purchase one or more Electronic Scratch Tickets. The pricing of tickets is

governed by the provisions of Section 8.13. Wagers are deducted from

the Game Play Credits displayed on the Player Terminal. (TSC X2 3.1.4)

Prize structure, ticket purchase and selection, and wager information is

displayed or available on the Player Terminal with respect to any game

which is being played through that Terminal. (TSC X2 3.1.5)

After the player purchases an Electronic Scratch Ticket the outcome

associated with that ticket is shown on the Player Terminal. Any prizes

won are displayed on the Player Terminal and may be in the form of

Game Play Credits, the right to receive merchandise, or other valuable

property. (TSC X2 3.1.6)

Game Play Credits earned as prizes remain displayed and available for

use in further play from that Terminal. Game Play Credits also may be

electronically transferred to a) a player’s account in the Central

Accounting System, b) a ticket or receipt printed by the Player Terminal,

or c) a "smart" card or similar instrument. Once transferred, Game Play

Credits may be a) used for further play on another Terminal or b)

redeemed for cash or cash equivalents through a cashier or other

separate redemption system. Merchandise or other property won is

collected in accordance with the rules of the game. (TSC X2 3.1.7)

8.12. Ticket Lottery System (TLS)TLS Cashless Transaction Security, Reporting and

Storage Requirements

The following requirements shall be met in connection with any Cashless

Transaction System: (TSC X2 8.1)

All player information must be stored on at least two separate non-volatile

media; (TSC X2 8.1.1)

An audit file must be kept of all player financial transactions. This file must be

stored in at least two separate non-volatile media, and be accessible for

purposes of audit and dispute resolution to authorized individuals; this file must

be available on-line for a minimum of 30 days, after which it must be available

off line for a minimum of 180 days; (TSC X2 8.1.2)

Physical and operational controls must be used to protect player information

from tampering or unauthorized access; (TSC X2 8.1.3)

Passwords or personal identification numbers (PINs), if used, must be protected

from unauthorized access; (TSC X2 8.1.4)

All player information shall be accurately recorded and such recording protected

by the system; (TSC X2 8.1.6)

Any card or other tangible instrument issued to a player for the purpose of using

the Cashless Transaction System shall bear on its face a control or inventory

number unique to that instrument; (TSC X2 8.1.7)

Encoded bearer instruments printed or magnetic may include coupons and other

items distributed or sold for game play, promotional, advertising or other

purposes, but may not include cash. Such instruments must be in electronically

readable form in addition to having unique identification information printed on

the instrument face. The daily and monthly reporting must include with respect

to such instruments:

Cash converted to value in the cashless system

Outstanding unredeemed balance:

Value in the cashless system converted to cash;

Amount wagered; and

Amount won. (TSC X2 8.1.8)

Redemption periods, if any, shall be posted or otherwise disclosed to all players.

(TSC X2 8.1.9)

Vouchers must bear on the face, in addition to the unique serial number, the

following:

Time/Date printed;

Unique identification from which it was printed; and

Value of voucher. (TSC X2 8.1.10)

8.13. TLS Game Set and Subset Requirements (TSC X2 3.2) Each Game Set shall meet

the following minimum requirements:

Each Game Set shall be made up of a finite number of Electronic Scratch Tickets;

All Scratch Tickets in a particular Game Set shall be of the same purchase price,

which shall not exceed $5.00, with the exception that up to 15 percent of the

Player Terminals in operation may have purchase prices of up to $20.00 per

Ticket. A single Ticket may offer an opportunity to enter another Game Set;

The payout percentage for the entire Game Set shall be no less than 75% of the

total purchase price of all tickets in the set combined;

Each Game Set shall be assigned a unique serial number; and

Each ticket shall have a specific outcome and prize level associated with it. (TSC X2

3.2.1)

8.14. TLS Game Set Verification Process.

Prior to commencement of play, the initial Game Set shall be verified as to the

total number of tickets in the set and the number of winners at each prize level,

including the amounts of such prizes, and the number of non-winners. The

verification standards which the Game Set must meet are those set forth in

Section 8.18. (TSC X2 3.2.2)

8.15. TLS Transmission of Subsets to Central Computer.

Following verification of the Game Set, the Manufacturing Computer shall create

ordered Scratch Ticket Subsets on demand from the Central Computer and

transmit the ordered Subsets to it. (TSC X2 3.2.3)

8.16. TLS Subset Requirements.

Each Electronic Scratch Ticket Game Subset shall meet the following minimum

requirements:

Within a given Game Set, each Subset shall be the same size and

comprised of no less than 5,000, and no more than 10,000 Electronic

Scratch Tickets, provided that in order to complete the distribution of all

tickets in a Game Set, the final Subset derived from the Set may have less

than the number of tickets in any other Subset and be less than 5,000;

Each Subset shall be individually and uniquely identified by the Game Set

serial number and a unique serial number for each Subset assigned in the

order in which the Subsets are created;

Once an Electronic Scratch Ticket has been dispensed to a Player

Terminal from a Subset, it cannot be dispensed again. (TSC X2 3.2.4)

8.17. TLS Completion of Game.

A Scratch Ticket Game is deemed to be completed only when all of the Electronic

Scratch Tickets in a Game Set have been dispensed or the Game Set has been

taken out of play. If any Game Set is withdrawn from play before completion of

the Game, the Tribe shall ensure that at least 75% of the revenues received from

sales of Electronic Scratch Tickets in that Game have been, or in future Electronic

Scratch Ticket Games will be, awarded to players. (TSC X2 3.2.5)

8.18. TLS Data Required Prior to Commencement of an Electronic Scratch Ticket

Game.

The following data shall be available to the TGA and SGA prior to the

commencement of an Electronic Scratch Ticket Game and shall be maintained

and be viewable both electronically and if requested, by printed report, upon

demand: (TSC X2 3.3)

A unique identifying Game Set serial number; (TSC X2 3.3.1)

A description of the Game Set theme sufficient to categorize the Game

Set relative to other Game Sets; (TSC X2 3.3.2)

The number of total Scratch Tickets in the Game Set; (TSC X2 3.3.3)

The number of Scratch Ticket Subsets to be created from the Game Set,

and the number of tickets in each Set; (TSC X2 3.3.4)

The payout percentage of the entire Game Set; (TSC X2 3.3.5)

The payout table for the Game Set and the number of Scratch Tickets at

each level of the payout table; (TSC X2 3.3.6)

The purchase price per ticket assigned to the Game Set; (TSC X2 3.3.7)

Such further information as the SGA may reasonably require to assure

the integrity and accuracy of the foregoing information. (TSC X2 3.3.8)

8.19. TLS Data Required to be Available Following the Completion of a Scratch

Ticket Game.

Following the completion of an Electronic Scratch Ticket Game (i.e., upon the

sale of all tickets in a Game Set or the withdrawal of the Set from play), the

following data shall be available to the TGA and SGA and shall be maintained and

viewable both electronically and if requested, by printed report, upon demand:

(TSC X2 3.4)

The Game Set and Game Subsets serial numbers; (TSC X2 3.4.1)

The total number of Electronic Scratch Tickets unsold, if the game is

removed from play; (TSC X2 3.4.2)

The total number of Electronic Scratch Tickets purchased; (TSC X2 3.4.3)

The time and date that each Subset was transmitted to the Central

Computer; (TSC X2 3.4.4)

The time and date that the game was completed or removed from play;

The final payout percentage of the game; and (TSC X2 3.4.6)

Price per Ticket. (TSC X2 3.4.7)

(TSC X2 3.4.5)

8.20. TLS Software Auditing Tool to be Made Available.

For auditing Game Sets and Subsets that have been archived, any Tribal Lottery

System shall include and have available for the SGA and the TGA a secure

software tool which provides the same data as set forth in Section 8.18 and 8.19,

provided that such tool shall be used only during authorized audits of Tribal

Lottery System games and operations, or in cases of player disputes, and shall

not be used for any other purpose without the consent of the TGA and the SGA.

(TSC X2 3.5)

8.21. TLS No Audit of Set While in Play; Dispute Process

No Audit of Set While in Play In order to provide maximum game integrity, no

audit or other determination of the status of any Game Set or any Subset,

including but not limited to a determination of the prizes won or prizes

remaining to be won, shall be conducted by anyone, including TGA and SGA

personnel, while a Subset is in play without causing termination of the entire

Game Set from which the Subset was derived as provided in paragraph C of this

section. (TSC X2 3.6.1)

Dispute Resolution: Impact on Game Set Play. In the event of a dispute by a

player that cannot be resolved by ordinary means by Gaming Facility personnel

as to the outcome, prize, wager made, or any other aspect of the player's

participation in a Game Set being played, all relevant data shall be immediately

collected, including but not limited to all meter readings, memory records,

surveillance recordings, and any other reports or information regarding play at

the Terminal for the play in dispute. Following the collection of all relevant data,

the TGA shall be notified and requested to make an evaluation of whether or not

the dispute involves the integrity of the hardware or software being used and to

try and resolve the dispute. A report of all disputes shall be maintained by the

TGA. If the dispute is not resolved within 72 hours from the time of the

complaint, the TGA shall immediately forward a report to the SGA detailing the

nature of the dispute. In the event the dispute is resolved, the TGA is not

obligated to report to the SGA, but shall make TGA reports available for review.

(TSC X2 3.6.2)

Termination of Game Set. Protection of game integrity, even if it requires the

early withdrawal of a Game Set from play, shall be the primary goal of this

Appendix. If resolution of a patron dispute requires access to data or records

stored on any part of a system other than the Player Terminal involved in the

dispute, and such access can only be accomplished through a means by which

data would be revealed that could materially assist anyone in determining the

likelihood of a particular ticket being drawn, other than information available to

all patrons, the Game Set shall be terminated prior to accessing such data or

records. (TSC X2 3.6.3)

TGA/SGA Disputes. In the event there is a dispute between the TGA and SGA at

any point in the above process, it shall be resolved in accordance with the

dispute resolution process for such issues set forth in the Compact. (TSC X2 3.6.4)

8.22. TLS Manufacturing Computer (TSC X2 3.7)

Security from Alteration, Tampering, or Unauthorized Access. The

Manufacturing Computer shall provide a physical and electronic means, by use

of a password or other method approved by the TGA and SGA, for securing the

Game Set against alteration, tampering, or unauthorized access. The

Manufacturing Computer shall provide a means for terminating the Game Set if

unopened ticket information from an operating Game Set or Subset has been

accessed except as permitted in this Appendix. The Gaming Test Laboratory shall

certify that such security system, and a means for monitoring its use in

accordance with this Appendix, is included in the system before it may be

authorized for use. Security systems and monitoring may be required for any

component that has electronic access to this system that may violate the

integrity and security of the manufacturing computer. (TSC X2 3.7.1)

Primary Purpose; Separation. The Manufacturing Computer shall be dedicated

primarily to those Tribal Electronic Scratch Ticket gaming system functions

related to the creation of Scratch Ticket Game Sets and the creation,

randomization, and transmittal to the Central Computer of Scratch Ticket

Subsets. Notwithstanding the foregoing, the Manufacturing Computer may also

be used for other computer functions in the Tribal Lottery System or Electronic

Accounting System if such use will not affect the integrity or outcome of any

game. (TSC X2 3.7.2)

Storage Medium; Backup. The Manufacturing Computer shall have a medium for

securely storing Electronic Scratch Ticket Game Sets and Subsets on the

Manufacturing Computer which shall be mirrored on line by a backup medium

within the same cabinet or enclosure. In addition, duplicates of the Sets and

Subsets, as created and stored on the Manufacturing Computer, shall be stored

in a secure enclosure in the Gaming Facility separate from the Manufacturing

Computer. All storage shall be through an error checking, nonvolatile physical

medium, so that should the primary storage medium fail, there will be no critical

data loss. (TSC X2 3.7.3)

Randomization. The Manufacturing Computer shall utilize randomizing

procedures in the creation of the Subsets. The randomizing procedures shall be

in accordance with Section 6 of this Appendix. (TSC X2 3.7.4)

8.23. TLS Central Computer Used in Connection with Electronic Scratch Ticket

Game.

The following requirements apply to any Central Computer used in connection

with an Electronic Scratch Ticket Game. (TSC X2 3.8)

Dispensing of Tickets. The Central Computer shall dispense, upon

request from a Player Terminal, Electronic Scratch Tickets. (TSC X2 3.8.1)

Order of Scratch Tickets. The Central Computer shall maintain Electronic

Scratch Ticket Subsets in the order received from the Manufacturing

Computer, and transmit them in that order to Player Terminals on

demand, provided that not less than two (2) nor more than five (5)

Subsets per Game Set shall be dispensed in accordance with a

predetermined order for rotating the Subsets. Subsets from more than

one Game Set may be stored on the Central Computer and made

available for play at the same time. (TSC X2 3.8.2)

Storage Medium; Backup. The Central Computer shall have a medium for

storing Electronic Scratch Ticket Game Subsets and reflecting their

current status of play, which shall be mirrored on line by a backup

medium within the same cabinet or enclosure. All storage shall be

through an error checking, nonvolatile physical medium, so that should

the primary storage medium fail, there will be no critical data loss. (TSC X2

3.8.3)

No Randomization Capability. The Central Computer shall have no

randomization capability associated with its use in an Electronic Scratch

Ticket game. (TSC X2 3.8.4)

8.24. TLS Data Available for Inspection.

The following data is required to be available for inspection in compliance with

Appendix X2, Section 7.1.9 for any Player Terminal or Game Set: (TSC X2 3.10)

All Game Set serial numbers, indicating the date and time the Game Set

was put in play, pulled from play, or completed. (TSC X2 3.10.1)

By Game Set serial numbers, the Player Terminal numbers assigned, and

the dates and times of assignment to the Player Terminals. (TSC X2 3.10.2)

8.25. Player Terminals.

All Player Terminals shall conform at a minimum to the requirements of this Section.

Use as a Stand-Alone Gambling Device Prohibited. No Player Terminal shall be

capable of being used as a stand-alone unit for the purposes of engaging in any

gambling game, including but not limited to the lottery games described in this

Compact, or in any other way prohibited in this Appendix. (TSC X2 5.1)

Player Terminals shall include the following features:

Operation either through the Cashless Transaction System, or through

means for accepting cash (coins, tokens or paper currency) for conversion

into Game Play Credits, which can then activate participation in the

game, provided the insertion of cash will not alone activate the game and

such use of cash is in accordance with Section 8.29; (TSC X2 5.2.1)

One or more of the following: A video monitor, electro-mechanical

display, printer, graphics and signage, provided that slot machine-type

spinning reel mechanisms are prohibited in mechanical form; and (TSC X2

5.2.2)

One or more of the following: electronic buttons, touch screen capability,

and a mechanical, electro-mechanical or electronic means of activating

the game and providing player input, including a means for making player

selections and choices in games, provided that slot machine type handles

are prohibited. (TSC X2 5.2.3)

Non volatile backup memory or its equivalent shall be maintained in a secure

compartment on each Player Terminal for the purpose of storing and preserving

a redundant set of critical data which has been error checked in accordance with

this Appendix, and which data shall include, at a minimum, the following Player

Terminal information: (TSC X2 5.3)

Recall of all wagers and other information associated with the last ten

(10) Electronic Scratch Ticket plays and the last ten (10) On-line Lottery

Games played; (TSC X2 5.3.2)

Error conditions that may have occurred on the Player Terminal; and (TSC

Recall of the last twenty five (25) cash or cash equivalent deposits. (TSC X2

X2 5.3.3)

5.3.4)

An on/off switch that controls the electrical current that supplies power to the

Player Terminal must be located in a secure place that is readily accessible within

the interior of the Player Terminal.

The operation of each Player Terminal must not be adversely compromised or

affected by static discharge, liquid spills, or electromagnetic interference. (TSC X2

5.5)

A Player Terminal must have electronic accounting meters which have tally totals

to a minimum of eight (8) digits and be capable of rolling over when the

maximum value of at least 99,999,999 is reached. The Player Terminal must

provide a means for on-demand display of the electronic meters via a key switch

or other secure method on the exterior of the machine. Electronic meters on

each Player Terminal for each of the following data categories for Electronic

Scratch Ticket games and On-line Lottery Games are required in compliance with

Appendix Xw2, Section 7.1.9: (TSC X2 5.6)

Credits, or equivalent monetary units, wagered on a cumulative basis on

that Terminal; (TSC X2 5.6.1)

Credits, or equivalent monetary units, won for the Player Terminal; (TSC X2

For Scratch Ticket games, the number of Scratch Tickets purchased on

the Terminal; and (TSC X2 5.6.3)

For On-line Lottery games, the number of On-line Lottery wagers made

on that Terminal. (TSC X2 5.6.4)

5.6.2)

Under no circumstances shall the Player Terminal electronic accounting meters

be capable of being automatically reset or cleared, whether due to an error in

any aspect of its or a game's operation or otherwise. All meter readings must be

recorded and dated in the presence of a TGA inspector both before and after an

electronic accounting meter is cleared. (TSC X2 5.7)

At a minimum, each Player Terminal shall have the following game information

available for display on the video screen and/or displayed on the Player Terminal

itself, in a location conspicuous to the player: (TSC X2 5.8)

The rules of the game being played; (TSC X2 5.8.1)

The maximum and minimum wagers and the amount of credits, cash

equivalents, or additional game play opportunities, which may be won for

each Electronic Scratch Ticket and On-line Lottery Game offered through

that Terminal, including the current values of any progressive prizes

available; (TSC X2 5.8.2)

The player's credit balance; (TSC X2 5.8.3)

The outcome of the Electronic Scratch Ticket(s) then being played; and

(TSC X2 5.8.4)

Any prize won on the Electronic Scratch Ticket(s) then being played. (TSC

X2 5.8.5)

The video screen or other means for displaying game rules, outcomes and other

game information shall be kept under a glass or other transparent substance

which places a barrier between the player and the actual surface of the display.

At no time may stickers or other removable media be placed on the Player

Terminal's face for purposes of displaying rules or payouts. (TSC X2 5.9)

No hardware switches may be installed on a Player Terminal or any associated

equipment which may affect the outcome or pay out of any game for which the

Player Terminal is used. Switches may be installed to control the ergonomics of

the Player Terminal. (TSC X2 5.10)

The Player Terminal shall record the date and time of any opening of cabinet

door(s); provided, that this information need not be retained on the Player

Terminal if it is communicated to another component of the system. This

information shall be retrievable in report form. (TSC X2 5.16)

Player Terminals shall not have software or hardware that determines the

outcome of any Electronic Scratch Ticket Game. Nothing herein is intended to

prohibit the Player Terminal from creating the appropriate Scratch Ticket and

On-line Game graphics and animation to correspond to, display or represent, in

an entertaining manner, the outcome. In addition, Player Terminals shall not

have any software that: (TSC X2 5.12)

Determines which Scratch Ticket outcome from within the Scratch Ticket

Subset is transmitted to the Player Terminal; or (TSC X2 5.12.1)

Alters the amount of the payout of the Electronic Scratch Ticket as

received from the Central Computer. (TSC X2 5.12.2)

Nothing herein shall prohibit the use of a quick pick function on the Player

Terminal in conjunction with the playing of the On-line Lottery Game. (TSC X2 5.13)

Players shall make wagers using a Player Terminal to purchase Electronic Scratch

Tickets. Following a purchase, the Electronic Scratch Ticket shall be displayed on

the Terminal's video screen for the purpose of revealing the outcome of the

selected ticket. (TSC X2 5.14)

8.26. TLS Networking Requirements.

The use of firewalls and other system protections as approved by TGA and SGA

are required to protect the integrity of the Tribal Lottery System and player

accounts and: (TSC X2 5.11)

Where the Tribe’s Tribal Lottery System or components are linked with

one another in a local network for progressive jackpot, function sharing,

aggregate prizes or other purposes, communication protocols must be

used which ensure that erroneous data or signals will not adversely affect

the operations of any such system or components. No class III game or

gaming system in which any part or component is located outside the

Tribe’s gaming facilities shall be deemed approved as part of the approval

of this Appendix. Any proposal for such game or gaming system,

including the proposed rules, manner of regulation, and manner of play,

monitoring and/or maintenance of the system, shall require submission

to, and approval by, the TGA and SGA. (TSC X2 5.11.1)

Dedicated and protected network connections prohibiting unauthorized

access, approved by SGA and TGA, may allow two or more of the Tribe’s

Tribal Lottery Systems to share player information. Game tickets and

other information prohibited from being viewed, as outlined in other

sections of this Appendix, shall not be available or transmitted between

the Tribe’s connected Tribal Lottery Systems or facilities.

Communications between the Tribe’s facilities will require the use of

approved firewalls that are configured and operated to protect the Tribal

Lottery System and player information. Computer systems linked

between the Tribe’s facilities may not be used to link progressive

jackpots, except in Joined Facilities. (TSC X2 5.11.2)

8.27. TLS Security Requirements.

The following requirements apply to all components of the Tribal Lottery System,

including the Manufacturing Computer, the Central Computer, the Electronic

Accounting System and Player Terminals. (TSC X2 9)

The Manufacturing Computer, Central Computer, and Player Terminals in

each Tribal Lottery System shall be physically and operationally

independent from one another except as specified otherwise in this

Appendix, such as for communications, storage and security monitoring,

including the routing of communications among system components,

provided such routing does not affect the integrity of the

communications or the outcome of any game. All Tribal Lottery System

cables shall be secured against unauthorized access. (TSC X2 9.1)

Live network jacks shall be locked to prevent someone from

removing the legitimate connection and plugging in an

unauthorized device.

Network jacks and cables that are not being utilized will either be

locked or physically disconnected from the network so they are

no longer active.

The Manufacturing Computer and Central Computer must be in a locked,

secure enclosure with both camera coverage and key controls in place.

Routers, switches, hubs, or other network access points, to include

management terminals and terminals not separated from the Tribal

Lottery System by firewalls approved by the WSGC and TGA, must also be

in a locked, secure enclosure with both camera coverage and key controls

in place. Access to Manufacturing Computers and Central Computers

shall be logged by the system to include the date and time of access and

available to WSGC and TGA upon request. (TSC X2 9.2)

The TLS remote workstation Central Processing Unit shall at a

minimum be enclosed in a locked and monitored cabinet. Keys to

the cabinet shall be maintained in accordance with the approved

Tribal Operations Internal Controls.

Remote workstations shall prevent access to the network or

application based tools that allow access to restricted gaming

information. In addition, any account information access must

follow approved internal controls.

Connections between all components of the Tribal Lottery System shall

only be through the use of secure communication protocols which are

designed to prevent unauthorized access or tampering, employing Data

Encryption Standards (DES) or equivalent encryption with changeable

seeds or algorithms. (TSC X2 9.3)

Each component of the Tribal Lottery System shall at all times be

connected to a device which provides surge protection on any line that

feeds it and, with the exception of Player Terminals, shall be connected

to a temporary power source, such as a UPS, to provide means for an

orderly shutdown of the computer in the event of a main power system

failure. (TSC X2 9.4)

A non-removable plate shall be affixed to the exterior of each Player

Terminal which shall have written upon it the Terminal's serial number

and model number of the component and name of the manufacturer.

Other audit numbers may be required to be affixed to provide a means of

identifying individual Terminals for correlation to required reports. (TSC X2

9.5)

The Manufacturing and Central Computers shall at a minimum be

enclosed in a locked and monitored cabinet. Access shall be through the

use of access controls provided in paragraph 7 of this section. The Player

Terminal shall have at a minimum the following separately locked areas,

which shall be the only means of accessing any non-public part of the

Terminal: (a) a locked and monitored cabinet door; (b) a locked

microprocessor compartment; (c) a locked outer cash box door; and (d) a

locked drop cash box door. (TSC X2 9.6)

Keys which provide access to any locked compartment, component or

area of a Tribal Lottery System, as well as passwords, keycards, or PIN

numbers used to access the Tribal Lottery System, shall be maintained

and used in accordance with the access control standards enacted in the

Tribe's statement of minimum internal controls. (TSC X2 9.7)

Each employee accessing the Tribal Lottery System software

except for Player Terminals and unattended Kiosks by means of a

password, keycard, or PIN number, including vendor

representatives, must have a user name or user number unique to

that individual, and the Tribal Lottery System must log the date

and time of access. These access logs must be readily available

for audit by TGA and WSGC. (TSC X2 9.7.1)

For all entries into the locked areas of the Manufacturing Computer,

Central Computer, unattended Kiosks, or any Player Terminal, a written

record must be made on a machine entry authorization log (MEAL)

indicating at least the following: the time, date, and purpose of entering

said locked area(s), and the name and employee number (or other

personal identification specific to such person) of the person doing so.

(TSC X2 9.8)

In addition to maintenance of MEAL cards, the Manufacturing and

Central Computers shall record and generate a report on any access

including date, time of access, person (by employee number) accessing

the computer, and the reason for access. (TSC X2 9.9)

10.

For purposes of this section, all components of the Tribal Lottery System,

except wiring, cables, and conduit in which they are located, shall have

the ability to be effectively and clandestinely monitored and recorded by

means of a closed circuit television system or digital surveillance system

in accordance with Appendix A and as authorized by TGA and SGA, in

compliance with the requirements of the Compact. (TSC X2 9.10)

11.

Overhead camera coverage should be sufficient to identify the

individual(s) accessing remote workstations. The coverage should

not include the keyboard so sensitive passwords cannot be

viewed and recorded. Coverage should be recorded real-time, full

screen, and on dedicated VCR’s or digital recorders.

In addition to its functions in operating a connection with the Electronic

Scratch Ticket and On-line Lottery Games, the Central Computer may be

used to record the data used to verify game play and to configure and

perform security checks on Player Terminals, provided such functions do

not affect the security, integrity or outcome of such games. (TSC X2 9.11)

The TLS Manufacturing Computer shall provide a physical and

electronic means, by use of a password or other method

approved by the TGA and State Gaming Agency, for securing the

Game Set against alteration, tampering, or unauthorized access.

(TSC X2 9.7.1)

8.28. BGS & EGM Requirements

Controls must be established, and procedures implemented to safeguard the

integrity of technological aids to the play of bingo during installations,

operations, modifications, removal and retirements. Such procedures must

include the following: (MICS 543.8(g)

Shipping and receiving MICS 543.8(g)(1)

A communication procedure between the supplier, the gaming

operation, and TGA to properly control the shipping and receiving

of all software and hardware components, including: (MICS 543.8(g)(1)

(1)

(2)

Notification of pending shipments to be provided to the TGA by

the gaming operation;

Certification in accordance with 25 CFR part 547;

(3)

Notification from the supplier to the TGA, or the gaming

operation as approved by the TGA, of the shipping date and

expected date of delivery. The shipping notification must

include:

(i) Name and address of the supplier;

(ii) Description of shipment;

(iii) For player interfaces: a serial number;

(iv) For software: software version and description of

software;

(v) Method of shipment; and

(vi) Expected date of delivery.

Procedures for the exchange of the gaming system components

for maintenance and replacement.

Procedures for shipping and receiving BGS components in a

secure manner to deter unauthorized access.

TGA, or its designee, must receive all the gaming system

components and game play software packages, and verify the

contents against the shipping notification.

Security and access control methods. (MICS 543.8(g)(2)

Physical and operational controls must be established to restrict

access to the gaming system components and protect player

information from tampering or unauthorized access.

Recordkeeping and audit processes. (MICS 543.8(g)(3)

The gaming operation must maintain the following records, as

applicable, related to installed game servers and player interfaces:

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

Date placed into service;

Date made available for play;

Supplier;

Software version;

Serial number;

Game title;

Asset and/or location number;

Seal number; and

Initial meter reading.

Procedures must be implemented for auditing such records.

System software signature verification. (MICS 543.8(g)(4)

Procedures must be implemented for system software

verifications. These procedures must include comparing

signatures to the signatures provided in the independent test

laboratory letter for that software version and/or the WSGC

website.

An agent independent of operation must perform system

software signature verification(s) to verify that only approved

software is installed.

Procedures must be implemented for investigating and resolving

any software verification variances.

Internal audits must be conducted. Such audits must be

documented.

Installation testing. (MICS 543.8(g)(5)

Testing must be completed during the installation process to

verify that the player interface has been properly installed. This

must include testing of the following, as applicable:

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

(10)

(11)

Communication with the gaming system;

Communication with the accounting system;

Communication with the player tracking system;

Currency and vouchers to bill acceptor;

Voucher printing;

Meter incrementation;

Pay table, for verification;

Player interface denomination, for verification;

All buttons, to ensure that all are operational and programmed

appropriately;

System components, to ensure that they are safely installed at

location; and

Locks, to ensure that they are secure and functioning.

Display of rules and necessary disclaimers. (MICS 543.8(g)(6)

The operation must ensure that all game rules and disclaimers are

displayed at all times or made readily available to the player upon

request,

TGA must verify that all game rules and disclaimers are displayed

at all times or made readily available to the player upon request.

TGA approval of all technologic aids before they are offered for play. (MICS

All the gaming equipment must comply with 25 CFR part 547, Minimum

Technical Standards for Gaming Equipment and also the Tribal-State

Compact for the Class III gaming; and (MICS 543.8(g)(8)

In the event of a dispute by a player that cannot be resolved by ordinary

means by Gaming Facility personnel as to the outcome, prize, wager

543.8(g)(7)

made, or any other aspect of the player's participation in a Game Set

being played, all relevant data shall be immediately collected, including

but not limited to all meter readings, memory records, surveillance

recordings, and any other reports or information regarding play at the

Terminal for the play in dispute. Following the collection of all relevant

data, the TGA shall be notified and requested to make an evaluation of

whether or not the dispute involves the integrity of the hardware or

software being used and to try and resolve the dispute. A report of all

disputes shall be maintained by the TGA. If the dispute is not resolved

within 72 hours from the time of the complaint, the TGA shall

immediately forward a report to the SGA detailing the nature of the

dispute. In the event the dispute is resolved, the TGA is not obligated to

report to the SGA but shall make TGA reports available for review. (MICS

543.8(g)(9)

Malfunctions. Procedures must be implemented to investigate, document and

resolve malfunctions. Such procedures must address the following: (MICS 543.8(h)(1)

Determination of the event causing the malfunction

Review of relevant records, game recall, reports, logs, surveillance

records;

Repair or replacement of the gaming component;

Verification of the integrity of the gaming component before restoring it

to operation.

Removal, retirement and/or destruction. Procedures must be implemented to

retire or remove any or all associated components of a gaming system from

operation. Procedures must include the following (543.8(h)(2)

For player interfaces and components that accept cash or cash

equivalents:

Coordinate with the drop team to perform a final drop;

Collect final accounting information such as meter readings, drop

and payouts;

Remove and/or secure any or all associated equipment such as

locks, card reader, or ticket printer from the retired or removed

component; and

Document removal, retirement, and/or destruction.

For removal of software components:

Purge and/or return the software to the license holder; and

Document the removal.

For other related equipment such as blowers, cards, interface cards:

Remove and/or secure equipment; and

Document the removal or securing of equipment.

For all components:

Verify that unique identifiers, and descriptions of removed/retired

components are recorded as part of the retirement

documentation; and

Coordinate with the accounting department to properly retire the

component in the system records.

Where TGA authorizes destruction of any gaming system components,

procedures must be developed to destroy such components. Such

procedures must include the following:

Methods of destruction;

Witness or surveillance of destruction;

Documentation of all components destroyed; and

Signatures of agent(s) destroying components attesting to

destruction.

8.29. EGS Audit and Accounting Standards.

When cash is used, the following procedures shall be performed by

accounting/auditing employees who are independent of the transactions being

reviewed: (TSC X2 5.15)

For each drop period, accounting/auditing employees shall compare the report

information required in Appendix X2, Section 7.1.10 (a) to the total cash

acceptor drop amount for the period. Discrepancies shall be resolved before the

generation/distribution of any statistical reports. (TSC X2 5.15.1)

TGA will be notified and follow-up shall be performed for any one machine

having an unresolved variance between actual cash drop and the report

information required in Appendix X2, Section 7.1.10 (a) in excess of an amount

that is both more than $25 and at least three percent (3%) of the actual cash

drop. The follow-up performed and results of the investigation shall be

documented and maintained for inspection. (TSC X2 5.15.2)

At least annually, accounting/auditing and TGA personnel shall randomly verify

that EPROM or other equivalent game software media changes are properly

reflected in the analysis reports. (TSC X2 5.15.3)

Accounting/auditing employees shall review exception reports on a daily basis

for propriety of transactions and unusual occurrences. TGA will be notified in

writing of any unexplained or suspicious transactions or unusual occurrences.

(TSC X2 5.15.4)

All auditing procedures and any follow-up performed shall be documented and

maintained for inspection. (TSC X2 5.15.5)

Cash shall be removed from the Player Terminal in accordance with Tribal-State

Compact, Appendix A drop box and transportation standards for secure and

verifiable handling of cash receipts from electronic games. (TSC X2 5.15.6)

Chapter 9

9.1.

COMPLIMENTARY SERVICES & ITEMS

Supervision

Supervision must be provided as required for approval of complimentary

services by an agent(s) with authority greater than those being supervised. MICS

543.13(a)

9.2.

Complimentary Services or Items

Controls shall be established and procedures implemented for complimentary

services or items that address the following: MICS 543.13(b)

Agents authorized to approve the issuance of complimentary services or

items, including levels of authorization, as approved by TGA;

Limits and conditions on the approval and issuance of complimentary

services or items, as approved by TGA;

Making and documenting changes to conditions or limits on the approval

and issuance of complimentary services or items, as approved by TGA;

Documenting and recording the authorization, issuance, and redemption

of complimentary services or items, including cash and non-cash gifts;

Records must include the following for all complimentary items

and services equal to or exceeding an amount established by the

gaming operation and approved by TGA:

(1)

(2)

(3)

(4)

(5)

9.3.

Complimentary Services and Items Records

9.4.

Name of patron who received the complimentary service or

item;

Name(s) of issuer(s) of the complimentary service or item;

The actual cash value of the complimentary service or item;

The type of complimentary service or item (i.e., food,

beverage); and

Date the complimentary service or item was issued.

Complimentary services and items records must be summarized and reviewed

for proper authorization and compliance with established authorization

thresholds. MICS 543.13(c)

A detailed reporting of complimentary services or items equal to or

exceeding $100 or an amount established by the Tribal gaming operation,

which shall not be greater than $100 must be prepared at least monthly.

The detailed report must be forwarded to management for review.

Variances

Any variance in excess of $25.00 shall be reviewed to determine the cause. Any

such review must be documented. MICS 543.13(d)

Chapter 10 CAGE, VAULT, KIOSK, & CASH EQUIVALENTS

10.1. Supervision

Supervision must be provided as required for cage, vault, kiosk, and other

operations using cash or cash equivalents by an agent(s) with authority greater

than those being supervised. MICS 543.18(a)

10.2. Check Cashing MICS 543.18(b)

If checks are cashed at the cage, the controls must provide for security and

integrity. For each check cashing transaction, the agent(s) conducting the

transaction must:

Verify the patron's identity;

Examine the check to ensure it includes the patron's name, current

address, and signature;

For personal checks, verify the patron's check cashing authority and

record the source and results in accordance with management policy;

however

If a check guarantee service is used to guarantee the transaction and the

procedures required by the check guarantee service are followed, then

the above requirements do not apply.

When traveler's checks or other guaranteed drafts, such as cashier's checks, are

presented, the cashier must comply with the examination and documentation

procedures as required by the issuer.

If a third party check cashing or guarantee service is used, the examination and

documentation procedures required by the service provider apply, unless

otherwise provided by tribal law or regulation.

10.3. Cage and Vault Accountability MICS 543.18(c)

All transactions that flow through the cage must be summarized for each work

shift of the cage and must be supported by documentation.

Increases and decreases to the total cage inventory must be verified, supported

by documentation, and recorded. Documentation must include the date and

shift, the purpose of the increase/decrease, the agent(s) completing the

transaction, and the person or department receiving the cage funds (for

decreases only). Unverified transfers of cash and/or cash equivalents are

prohibited. (MICS 542.14(d)(2))

The cage and vault inventories (including coin rooms) must be counted

independently by at least two agents, attested to by signature, and recorded in

ink or other permanent form at the end of each shift during which the activity

took place. These agents must make individual counts to compare for accuracy

and maintain individual accountability. All variances must be documented and

investigated.

The gaming operation must establish and comply with a minimum bankroll

formula to ensure the gaming operation maintains cash or cash equivalents (on

hand and in the bank, if readily accessible) in an amount sufficient to satisfy

obligations to the gaming operation's patrons as they are incurred. Minimum

bankroll calculations shall be completed at least annually.

10.4. Kiosks MICS 543.18(d)

Kiosks must be maintained on the cage accountability and must be counted

independently by at least two agents, documented, and reconciled for each

increase or decrease to the kiosk inventory.

Currency cassettes must be counted and filled by an agent and verified

independently by at least one agent, all of whom must sign each cassette.

Currency cassettes must be secured with a lock or tamper resistant seal and, if

not placed inside a kiosk, must be stored in a secured area of the cage/vault.

Kiosks shall have dedicated video surveillance through the use of a fixed camera

or dedicated PTZ. Coverage will be recorded in real-time, full screen, and on

dedicated digital recorders. TSC App. X2:8.4

The gaming operation, subject to the approval of TGA, must develop and

implement physical security controls over the kiosks. Controls should address

the following: forced entry, evidence of any entry, and protection of circuit

boards containing programs.

With regard to cashless systems, the gaming operation, subject to the approval

of TGA, must develop and implement procedures to ensure that communications

between the kiosk and system are secure and functioning.

The following reconciliation reports must be available upon demand for each

day, shift, and drop cycle (this is not required if the system does not track the

information, but system limitation(s) must be noted):

Starting balance dollar amount per financial instrument;

Starting balance number of items per financial instrument;

Dollar amount per financial instrument issued;

Number of items per financial instrument issued;

Dollar amount per financial instrument issued;

Number of items per financial instrument redeemed;

Dollar amount per financial instrument increases;

Number of items per financial instrument increases;

Dollar amount per financial instrument decreases;

10.

Number of items per financial instrument decreases;

11.

Ending balance dollar amount per financial instrument; and

12.

Ending balance number of items per financial instrument.

10.5. Patron Deposited Funds MICS 543.18(e)

If a gaming operation permits a patron to deposit funds with the gaming

operation at the cage, and when transfers of patron deposited funds are

transferred to a gaming area for wagering purposes, the following standards

apply:

The receipt or withdrawal of a patron deposit must be documented, with

a copy given to the patron and a copy remaining in the cage.

Both copies of the document of receipt or withdrawal must contain the

following information:

Same receipt number on each copy;

Patron's name and signature;

Date of receipt and withdrawal;

Dollar amount of deposit/withdrawal (for foreign currency

transactions include the US dollar equivalent, the name of the

foreign country, and the amount of the foreign currency by

denomination);

Nature of deposit/withdrawal; and

Name and signature of the agent who conducted the transaction.

Procedures must be established and complied with for front money

deposits to:

Maintain a detailed record by patron name and date of all funds

on deposit;

Maintain a current balance of all patron deposits that are in the

cage/vault inventory or accountability; and

Reconcile the current balance with the deposits and withdrawals

at least daily.

10.6. Promotional Payments, Drawings, and Giveaway Programs MICS 543.18(f)

The following procedures must apply to any payment resulting from a

promotional payment, drawing, or giveaway program disbursed by the cage

department or any other department. This section does not apply to payouts for

card game promotional pots and/or pools.

All payments must be documented to support the cage accountability.

Payments above $500 must be documented at the time of the payment, and

documentation must include the following:

Date and time;

Dollar amount of payment or description of personal property;

Reason for payment; and

Patron's name and confirmation that identity was verified (drawings

only).

Signature(s) of at least two agents verifying, authorizing, and completing

the promotional payment with the patron. For computerized systems

that validate and print the dollar amount of the payment on a computer

generated form, only one signature is required.

10.7. Chip(s) MICS 543.18(g)

Controls must be established and procedures implemented to ensure

accountability of chip inventory. Such controls must include, but are not limited

to, the following:

Purchase;

Receipt;

Inventory;

Storage; and

Destruction.

10.8. Vouchers MICS 543.18(h)

Controls must be established and procedures implemented to:

Verify the authenticity of each voucher redeemed.

If the voucher is valid, verify that the patron is paid the appropriate

amount.

Document the payment of a claim on a voucher that is not physically

available or a voucher that cannot be validated such as a mutilated,

expired, lost, or stolen voucher.

Retain payment documentation for reconciliation purposes.

For manual payment of a voucher of $500 or more, require a supervisory

employee to verify the validity of the voucher prior to payment.

Vouchers paid during a period while the voucher system is temporarily out of

operation must be marked “paid” by the cashier.

Vouchers redeemed while the voucher system was temporarily out of operation

must be validated as expeditiously as possible upon restored operation of the

voucher system.

Paid vouchers must be maintained in the cashier's accountability for

reconciliation purposes.

Unredeemed vouchers can only be voided in the voucher system by supervisory

employees. The accounting department will maintain the voided voucher, if

available.

10.9. Cage and Vault Access

Controls must be established and procedures implemented to: MICS 543.18(i)

Restrict physical access to the cage to cage agents, designated staff, and

other authorized persons; and

Limit transportation of extraneous items such as personal belongings,

tool boxes, beverage containers, etc., into and out of the cage.

As part of the Gaming Operation there shall be on or immediately

adjacent to the gaming floor a physical structure known as the Cashier's

Cage to house the cashiers and to serve as the central location for the

following (TSC App A:7(1)):

The custody of the cage inventory comprising currency, coin,

patron checks, gaming chips, forms, documents and records

normally associated with the operation of a cage.

The approval of patron checks for the purpose of gaming in

conformity with these standards

The receipt, distribution, and redemption of gaming chips in

conformity with these standards

Cashiers functions will be, but are not limited to the following (TSC App

A:8(2)):

Receive currency, coin, checks, gaming chips, vouchers, or Cash

Equivalents from patrons for gaming chip consolidations, total or

partial redemptions or substitutions

Receive documentation with signatures thereon, required to be

prepared for the effective segregation of functions in the cashier's

cage

Process fills and Credits by exchanging chips, currency, coin and

paperwork as authorized in these standards

Receive currency and coin from count rooms and kiosks

Prepare the overall cage reconciliation and accounting records

Perform such other functions as necessary to ensure proper

accountability consistent with these standards

Such other functions normally associated with the operation of a

cage.

Each cage will be designed and constructed to provide maximum security

including, at a minimum, the following (TSC App A:7(4)):

An enclosed structure except for openings through which items

such as gaming chips, checks, cash, records, and documents can

be passed to service the public and gaming stations

Manually triggered silent alarm systems connected directly to the

monitoring rooms of the Surveillance System

Access will be through a locked door

The system shall have Surveillance System coverage which will be

monitored by the surveillance department

The Tribal Gaming Operation will place on file with the Tribal Gaming

Agency the names of all persons authorized to enter the cage, those who

possess the combination or the Keys or who control the mechanism to

open the locks securing the entrance to the cage, and those who possess

the ability to operate the alarm system. TSC App. A:7(5)

10.10. Collection/Recording Checks Returned after Deposit TSC App. A:13

All dishonored checks returned by a bank ("returned checks") after deposit shall

be returned directly to, and controlled by accounting department employees.

No person other than one employed within the accounting department may

engage in efforts to collect returned checks except that a collection company or

an attorney-at-law representing the tribal gaming operation may bring action for

such collection. Any verbal or written communication with patrons regarding

collection efforts, shall be documented in the collection section.

Continuous records of all returned checks shall be maintained by accounting

department employees. Such records shall include, at a minimum, the following:

The date of the check;

The name and address of the drawer of the check;

The amount of the check;

The date(s) the check was dishonored;

The date(s) and amount(s) of any collections received on the check after

being returned by a bank.

The date and any amount written-off as uncollectible.

A check dishonored by a bank may be immediately re-deposited if there is

sufficient reason to believe the check will be honored the second time.

If a check is dishonored a second time, the name of the person who submitted

the check shall be kept in a log, and available to the cashier. Such person shall be

prohibited from submitting a future check until the amount owed is paid in full.

Any checks processed through an outside check guarantee company will not be

subject to the provisions of (A) through (E) above unless the Tribal Gaming

Operation chooses not to use their guarantee service to pre-approve a particular

check.

10.11. Variances

The operation must establish, as approved by TGA, the threshold level at which a

variance must be reviewed to determine the cause. This threshold must not

exceed $50.00. Any such review must be documented. MICS 543.18(j)

Chapter 11 INFORMATION TECHNOLOGY & DATA

A system is any computerized system that is integral to the gaming environment. This includes, but is

not limited to, the server and peripherals for the gaming systems, accounting, surveillance, essential

phone system, and door access and warning systems. 543.20(b)

11.1. Supervision 543.20(a)

Controls must identify the supervisory agent in the department or area

responsible for ensuring that the department or area is operating in accordance

with established policies and procedures.

The supervisory agent must be independent of the operation of the EGM.

Controls must ensure that duties are adequately segregated and monitored to

detect procedural errors and to prevent the concealment of fraud.

Information technology agents having access to the gaming systems may not

have signatory authority over financial instruments and payout forms and must

be independent of and restricted from access to:

Financial instruments;

Accounting, audit, and ledger entries; and

Payout forms.

11.2. Controls

Controls must be established and procedures implemented to ensure adequate:

MICS 543.20(c)

Control of physical and logical access to the information technology

environment, including accounting, voucher, cashless and player tracking

systems, among others used in conjunction with electronic gaming;

Physical and logical protection of storage media and its contents,

including recovery procedures;

Access credential control methods;

Record keeping and audit processes; and

Departmental independence, including, but not limited to, means to

restrict agents that have access to information technology from having

access to financial instruments.

11.3. Physical Security 543.20(d)

The information technology environment and infrastructure must be maintained

in a secured physical location such that access is restricted to authorized agents

only.

Access devices to the systems' secured physical location, such as keys, cards, or

fobs, must be controlled by an independent agent.

Access to the systems' secured physical location must be restricted to agents in

accordance with established policies and procedures, which must include

maintaining and updating a record of agents granted access privileges.

Network Communication Equipment must be physically secured from

unauthorized access.

11.4. Logical Security 543.20(e)

Controls must be established and procedures implemented to protect all

systems and to ensure that access to the following is restricted and secured:

Systems' software and application programs;

Data associated with electronic gaming; and

Communications facilities, systems, and information transmissions

associated with the gaming systems.

Unused services and non-essential ports must be disabled whenever possible.

Procedures must be implemented to ensure that all activity performed on

systems is restricted and secured from unauthorized access, and logged.

Communications to and from systems via Network Communication Equipment

must be logically secured from unauthorized access.

11.5. User Controls 543.20(f)

Systems, including application software, must be secured with passwords or

other means for authorizing access.

Management personnel or agents independent of the department being

controlled must assign and control access to system functions.

Access credentials such as passwords, PINs, or cards must be controlled as

follows:

Each user must have his or her own individual access credential;

Access credentials must be changed at an established interval approved

by TGA; and

Access credential records must be maintained either manually or by

systems that automatically record access changes and force access

credential changes, including the following information for each user:

User's name;

Date the user was given access and/or password change; and

Description of the access rights assigned to user.

Lost or compromised access credentials must be deactivated, secured or

destroyed within an established time period approved by TGA.

Access credentials of terminated users must be deactivated within an

established time period approved by the TGA.

Only authorized agents may have access to inactive or closed accounts of other

users, such as player tracking accounts and terminated user accounts.

11.6. Personnel Access Listing Standards TSC App. A:7(5); X2:9.7

A personnel access listing for the Player Account Server and all computerized

gaming systems shall be maintained which includes at a minimum:

Employee name;

Employee identification number (or equivalent); and

Listing of functions each employee can perform or equivalent means of

identifying this information.

11.7. Installations and/or Modifications 543.20(g)

Only TGA authorized or approved systems and modifications may be installed.

Records must be kept of all new installations and/or modifications to the gaming

systems. These records must include, at a minimum:

The date of the installation or modification;

The nature of the installation or change such as new software, server

repair, significant configuration modifications;

Evidence of verification that the installation or the modifications are

approved; and

The identity of the agent(s) performing the installation/modification.

Documentation must be maintained, such as manuals and user guides,

describing the systems in use and the operation, including hardware.

11.8. Remote Access 543.20(h)

Except for Tribal Lottery and Surveillance systems, Agents may be granted

remote access for system support, provided that each access session is

documented and maintained at the place of authorization. The documentation

must include:

Name of agent authorizing the access;

Name of agent accessing the system;

Verification of the agent's authorization;

Reason for remote access;

Description of work to be performed;

Date and time of start of end-user remote access session; and

Date and time of conclusion of end-user remote access session.

If authorized by Tribal-State Compact (TSC) Memorandums of Understanding

(MOU), remote access for the Tribal Lottery Systems and Surveillance System will

be permitted according to the precise conditions of the agreement. Remote

access to these systems is not permitted until TSC MOU’s for this purpose are

agreed to, and TGA has approved procedures developed by TGO to meet the

conditions of each agreement.

All remote access must be performed via a secured method as authorized by

CTGC.

Remote access to the Tribal Lottery System shall only be authorized in

accordance with an approved MOU between the Cowlitz Tribe and the State of

Washington.

11.9. Incident Monitoring and Reporting 543.20(i)

Procedures must be implemented for responding to, monitoring, investigating,

resolving, documenting, and reporting security incidents associated with

information technology systems.

All security incidents must be responded to within 72 hours and formally

documented with in fourteen (14) days .

A report shall be created within 30 days of the security incident. Such report(s)

shall be distributed to the IT Director, Compliance Officer and CTGC. The

Compliance Department shall report any items required by Title 31 to FinCEN.

11.10. Data Backups 543.20(j)

Controls, as approved by TGA must include adequate backup, including, but not

limited to, the following:

Daily data backup of critical information technology systems;

Data backup of critical programs or the ability to reinstall the exact

programs as needed;

Secured storage of all backup data files and programs, or other adequate

protection;

Mirrored or redundant data source; and

Redundant and/or backup hardware.

Controls, as approved by TGA must include recovery procedures, including, but

not limited to, the following:

Data backup restoration;

Program restoration; and

Redundant or backup hardware restoration.

Recovery procedures must be tested on a sample basis at specified intervals at

least annually. Results must be documented.

Backup data files and recovery components must be managed with at least the

same level of security and access controls as the system for which they are

designed to support.

11.11. Software Downloads 543.20(k)

Downloads, either automatic or manual, must be performed in accordance with

25 CFR 547.12.

11.12. Verifying Downloads 543.20(l)

Following download of any gaming system software, the gaming system must

verify the downloaded software using a software signature verification method.

Using any method it deems appropriate, TGA must confirm the verification.

Chapter 12 SURVEILLANCE

12.1. Supervision

Supervision must be provided as required for surveillance by an agent(s) with

authority greater than those being supervised. MICS 543.21(a)

12.2. Surveillance Equipment and Control Room(s) MICS 543.21(b)

Controls must be established and procedures implemented that include the

following:

The surveillance system must be maintained and operated from a staffed

surveillance operation room(s).

The surveillance operation room(s) must be secured to prevent

unauthorized entry.

Entrances to the Surveillance System monitoring room(s) shall not be

visible from the Gaming Facility area.

Access to the surveillance operation room(s) must be limited to

surveillance agents, agents of the Tribal Gaming Agency, State Gaming

Agency, and those specifically authorized by TGA.

Surveillance operation room(s) access logs must be maintained.

Surveillance operation room equipment must have total override

capability over all other satellite surveillance equipment.

Power loss to the surveillance system:

In the event of power loss to the surveillance system, an auxiliary

or backup power source must be available and capable of

providing immediate restoration of power to the surveillance

system to ensure that surveillance agents can observe all areas

covered by dedicated cameras.

The surveillance system must record an accurate date and time stamp on

recorded events. The displayed date and time must not significantly

obstruct the recorded view.

All surveillance agents must be trained in the use of the equipment,

games, and house rules.

10.

Each camera required by the standards in this section must be installed in

a manner that will prevent it from being readily obstructed, tampered

with, or disabled.

11.

A periodic inspection of the surveillance systems must be conducted.

When a malfunction of the surveillance system is discovered, the

malfunction and necessary repairs must be documented, and repairs

initiated within seventy- two (72) hours. MICS 543.21(b)(11)

If a dedicated camera malfunctions, alternative security

procedures, such as additional supervisory or security agents,

must be implemented immediately; and MICS 543.21(b)(11)(i)

TGA must be notified of any surveillance system and/or camera(s)

that have malfunctioned for more than twenty-four (24) hours

and the alternative security measures being implemented. MICS

543.21(b)(11)(ii)

12.

The surveillance system must:

Have the capability to display all camera views on a monitor;

Include sufficient numbers of recording devices to record the

views of all cameras required by this section;

Record all camera views required by this section;

Include sufficient numbers of monitors to simultaneously display

gaming and count room activities;

Have light sensitive cameras with zoom, scan and tilt capabilities

to effectively and clandestinely monitor in detail and from various

vantage point the following: App A:21(2)(a)

(1)

(2)

(3)

(4)

(5)

(6)

The Gaming activities conducted in the Gaming Facility;

ii.

The operations conducted at the cashier’s cage and

keno cage;

The entire count process and any other activities conducted in

the count room and the storage cabinets or trolleys used to

store Drop Boxes;

The movement of cash, gaming chips, and Drop Boxes in the

establishment; and

The entrances and exits to the Gaming Facility and the count

rooms.

Such other areas as the Tribal Gaming Agency designates.

Digital images record and playback images with sufficient

magnification and clarity that shows fluid motion and allows the

viewer to clearly distinguish the value of currency, coins, gaming

chips, playing cards, and outcome of the game and effectively

monitor in detail all areas in the gaming facility where Class III

gaming is conducted, including but not limited to table games;

TLS; poker; keno stations; cages; count rooms; information

technology department; and all gaming activity conducted by

gaming employees, patrons or players; AAR-2017-01

Be capable of audio recording the entire count process and any

other activities in the count room; TSC App. A:2(d)

Be equipped with an alarm that notifies the operator in the event

of an equipment malfunction.

Be password protected with only system administrator user rights

having the password to disable the erase and reformat functions.

13.

Adequate lighting shall be present in all areas, including the gaming floor,

where Surveillance System coverage is required.

14.

Digital surveillance suppliers may have periodic access to perform routing

upgrades and maintenance under the following conditions:

TGA must approve the remote access prior to it occurring;

A log must be kept of the remote access to include who is

accessing, time length of the remote access connection, and the

address of the remote connection.

All supplier representatives remotely accessing the Surveillance

System must be licensed by the Tribe and Certified by the State

Gaming Agency.

At no time will the supplier representatives have access to

manipulate or change live or recorded camera coverage.

12.3. Progressive Prize Meters Surveillance Standards

Surveillance of the progressive prize meters for the gaming systems at the

following thresholds:

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