# COWLITZ TRIBAL GAMING COMMISSION (2026) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/tribal%3Acowlitz%3A7d83ff630f7c9157 ## Record - **Collection:** Tribal code - **Document type:** Tribal code ## Text 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 A. 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 A. 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) B. 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 A. How do these regulations affect the Class III gaming minimum internal control standards established in the Tribal-State Compact? MICS 542.4 1. If there is a direct conflict between the Tribal-State Compact and this document, then the Tribal-State Compact shall prevail. 2. 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. 3. 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. A. The Tribal Gaming Operations (TGO) must develop and implement a System of Internal Control Standards (SICS) that, at a minimum, complies with the TICS. B. 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. C. 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 A. B. The gaming operation may request an alternate standard from those set forth in the TICS if the gaming operation: 1. Determines that it is unable to comply substantially with a standard in the TICS; and 2. 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: 1. An explanation of why the gaming operation is unable to comply substantially with the standard; 2. A description of the proposed alternate standards; and 3. An explanation of how the proposed alternate standard achieves at least the same level of control as the standard it is to replace. C. TGA may test the adequacy of the alternate standards. D. 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. E. 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: 1. 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 2. F. 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. G. 1. The Chair may approve or object to an alternate standard approved by TGA. 2. If the Chair approves the alternate standard, the TGO may continue to use it as authorized by the TGA. 3. 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. 4. 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. 5. 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 1. 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 A. 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. B. 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 A. 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. B. 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. C. The CPA shall prepare a report of the material weakness in accounting and system of internal controls for the Tribe and management. D. 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. E. 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 A. 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) B. These books or records shall be kept at all times and made readily available upon request for inspection by the authorized representatives of TGA. C. 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) D. 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 A. TGO shall submit initially, and upon each subsequent update, for review, discussion, and approval, all procedures established pursuant to the standards of the TICS. B. 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 A. 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) B. 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 A. Supervision must be provided as required for bingo operations by an agent(s) with authority greater than those being supervised. (MICS 543.8(a)) B. 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) A. 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): 1. Date; 2. Time; 3. Number of bingo cards sold; 4. Dollar amount of bingo card sales; and 5. Amount in, amount out and other associated meter information. Draw MICS 543.8(d)(2-4)(i-ii) A. 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. B. 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. C. Verification and display of draw. Controls must be established and procedures implemented to ensure that: 1. 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. 2. 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 A. B. Controls must be established and procedures implemented for cash or cash equivalents that address the following: (MICS 543.8(e)(1)) 1. Identification of the agent authorized (by position) to make a payout; 2. Predetermined payout authorization levels (by position); and 3. Documentation procedures ensuring separate control of the cash accountability functions. Verification of validity. (MICS 543.8(e)(2)) 1. C. D. E. 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: a) Winning card(s); b) Objects drawn; and c) The previously designated arrangement of numbers or designations on such cards. 2. At least two agents must verify that the card, objects drawn, and previously designated arrangement were valid for the game in play. 3. Where an automated verification method is available, verification by such method is acceptable. Validation. (MICS 543.8(e)(3)) 1. 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. 2. For automated payouts, the system may serve as the sole validator of the claim. Verification. (MICS 543.8(e)(4)) 1. 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. 2. 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)) 1. 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. 2. 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: F. 4.5. a) $5,000 for a Tier A facility; b) $10,000 at a Tier B facility; c) $20,000 for a Tier C facility; or d) $50,000 for a Tier C facility with over $100,000,000 in gross gaming revenues 3. The predetermined thresholds, whether set at the TICS level or lower, must be authorized by management, approved by TGA, documented, and maintained. 4. 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)) 1. Date and time; 2. Amount of the payout (alpha & numeric for player interface payouts); and 3. Bingo card identifier or player interface identifier. 4. Manual payout records must also include the following: a) Game name or number; b) Description of pattern covered, such as cover-all or four corners; c) Signature of all, but not less than two, agents involved in the transaction; d) For override transactions, verification by a supervisory or management agent independent of the transaction; and e) Any other information necessary to substantiate the payout. Cash and Cash Equivalent Controls MICS 543.8(f) A. 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. B. 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: 1. Inventory, including any increases or decreases; C. 4.6. 2. Transfers; 3. Exchanges, including acknowledging signatures or initials; and 4. 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) A. 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: 1. Shipping and receiving a) 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. 2. b) Procedures must be implemented for the exchange of the gaming system components for maintenance and replacement. c) Gaming system components must be shipped in a secure manner to deter unauthorized access. d) 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. a) 3. Controls must be established to restrict access to the gaming system components. Recordkeeping and audit processes. a) 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) b) 4. 5. 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. a) 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. b) An agent independent of operation must perform system software signature verification(s) to verify that only approved software is installed. c) Procedures must be implemented for investigating and resolving any software verification variances. d) Internal audits must be conducted. Such audits must be documented. Installation testing. a) 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) 6. 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. a) The operation must ensure that all game rules and disclaimers are displayed at all times or made readily available to the player upon request, b) 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 7. TGA approval of all technologic aids before they are offered for play. 8. 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 9. Dispute resolution. Operations MICS 543.8(h) A. B. Malfunctions - Procedures must be implemented to investigate, document and resolve malfunctions. Such procedures must address the following: 1. Determination of the event causing the malfunction; 2. Review of relevant records, game recall, reports, logs, surveillance records; 3. Repair or replacement of the gaming component; 4. 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: 1. 2. For player interfaces and components that accept cash or cash equivalents: a) Coordinate with the drop team to perform a final drop; b) Collect final accounting information such as meter readings, drop and payouts; c) Remove and/or secure any or all associated equipment such as locks, card reader, or ticket printer from the retired or removed component; and d) Document removal, retirement, and/or destruction. For removal of software components: 3. 4. 5. 4.8. a) Purge and/or return the software to the license holder; and b) Document the removal. For other related equipment such as blowers, cards, interface cards: a) Remove and/or secure equipment; and b) Document the removal or securing of equipment. For all components: a) Verify that unique identifiers, and descriptions of removed/retired components are recorded as part of the retirement documentation; and b) 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: a) Methods of destruction; b) Witness or surveillance of destruction; c) Documentation of all components destroyed; and d) Signatures of agent(s) destroying components attesting to destruction Vouchers MICS 543.8(i) A. Controls must be established and procedures implement to: 1. Verify the authenticity of each voucher redeemed. 2. If the voucher is valid, verify that the patron is paid the appropriate amount. 3. 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. 4. Retain payment documentation for reconciliation purposes. 5. 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. B. Vouchers paid during a period while the voucher system is temporarily out of operation must be marked “paid” by the cashier. C. 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. D. Paid vouchers must be maintained in the cashier's accountability for reconciliation purposes. E. 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) A. 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. 1. 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 A. 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. 1. 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. 2. A dealer may function as a supervisor if not dealing the game. Exchanges or Transfers A. 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. B. 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. C. 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 A. New and used playing cards must be maintained in a secure location, with appropriate surveillance coverage, and accessible only to authorized agents. B. 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. C. Playing cards associated with an investigation must be retained intact and outside of the established removal and cancellation procedure. Shill Funds A. Issuance of shill funds must be recorded and have the written approval of the supervisor. B. Returned shill funds must be recorded and verified by a supervisor. C. 5.5. Reconciliation of Card Room Bank A. 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: 1. Date; 2. Shift; 3. Table number; 4. Amount by denomination; 5. Amount in total; and 6. Signatures of both agents. Posted Rules A. 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. 1. 5.7. Prohibitions on side betting between and against player and against the house. Promotional Progressive Pots and Pools A. 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. 1. The payout may be in the form of personal property, such as a car. 2. A combination of a promotion and progressive pool may be offered. B. 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. C. 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: 1. Patron's name; 2. Date of payout; 3. Dollar amount of payout and/or nature and dollar value of any non-cash payout; 4. The signature of the agent completing the transaction attesting to the disbursement of the payout; and 5. Name of contest/tournament. D. 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. E. 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: 1. The amount of funds to be contributed from each pot; 2. What type of hand it takes to win the pool; 3. How the promotional funds will be paid out; 4. How/when the contributed funds are added to the pools; and 5. Amount/percentage of funds allocated to primary and secondary pools, if applicable. F. 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. G. The amount of the pools must be conspicuously displayed in the card room. H. At least once each day that the game is offered, the posted pool amount must be updated to reflect the current pool amount. I. 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. J. All decreases to the pool must be properly documented, including a reason for the decrease. K. Promotional funds removed from the card game must be placed in a locked container. 1. Agents authorized to transport the locked container are precluded from having access to the contents keys. 2. The contents key must be maintained by a department independent of the card room. 3. 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 A. 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. B. 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. C. 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 A. 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. B. The tribal gaming operation shall establish a procedure for accounting for all tips received by other gaming employees. C. 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) 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) A. 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: 1. The rules of play; 2. The nature and value of the associated prize(s) or cash award(s); 3. Any restrictions or limitations on participant eligibility; 4. The date(s), time(s), and location(s) for the associated promotional activity or activities; 5. Any other restrictions or limitations, including any related to the claim of prizes or cash awards; 6. The announcement date(s), time(s), and location(s) for the winning entry or entries; and 7. 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) A. 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. B. All other changes to the player tracking system must be appropriately documented. Player Tracking System Controls MICS 543.12(c)(2) A. 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.). B. 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. C. Employees who redeem points for members shall not have access to lost cards. Chapter 7 7.1. Supervision A. 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) A. 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: 1. The date and identification of the shift ended; 2. The game and station number; 3. The value of each denomination of gaming chips and coins, and total. 4. 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. B. 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. C. 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. D. Gaming chips or coins cannot be added to or removed from station inventory during the gaming day except: 1. In exchange for cash; 2. In payment of winning wagers and collection of losing wagers made at such gaming station; 3. In exchange for gaming chips received from a patron having an equal aggregate face value; and 4. In conformity with the fill and credit procedures described in these standards. Procedures for Opening Stations for Gaming TSC App. A:16(5) A. Gaming stations will be opened for gaming activity as follows: 1. The inventory container shall be unlocked in the presence of the Gaming Facility supervisor. 7.4. 7.5. 2. 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. 3. The Dealer and the Gaming Facility supervisor will sign the Opener. 4. 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. 5. 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) A. 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. B. The gaming chips and coins counted shall be recorded on a station inventory slip by the table games supervisor C. The Dealer and the table games supervisor, who observed the Dealer count, will sign the station inventory slip. D. 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. E. The triplicate copy of the station inventory slip shall be forwarded to the cashier’s cage by a Security Department Member. F. 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) A. 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. B. 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. C. 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. D. 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. E. 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 A. 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) B. 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) C. The original of the fill request shall be communicated to the cage where the fill slip is prepared. MICS 542.12(c)(4) D. At least three parts of each fill slip shall be utilized as follows: MICS 542.12(c)(5) E. 1. 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; 2. 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 3. 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. F. 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) G. All fills shall be carried from the cashier’s cage by a Security Department member. 542.12(c)(8) H. 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) 1. Cashier who prepared the fill slip and issued the chips, tokens, or monetary equivalent; 2. Security Department member who carried the chips, tokens, or monetary equivalents from the cage to the pit; 3. Dealer who received the chips, tokens, or monetary equivalents at the gaming table; and 4. Gaming Facility supervisor who supervised the fill transaction. I. 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) J. All fill slips requesting chips or money shall be prepared at the time a fill is made. K. 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 A. 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) B. 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) C. The original of the credit request shall be communicated to the cage where the credit slip is prepared. MICS 542.12(c)(12) D. At least three parts of each credit slip shall be utilized as follows: MICS 542.12(c)(13) 1. 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; 2. 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; 3. 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. E. 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) F. 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) G. 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) H. 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) 1. Cashier who received the items transferred from the pit and prepared the credit slip; 2. Security Department member who carried the items transferred from the pit to the cage and returned to the pit with the credit slip; 3. Dealer who had custody of the items prior to transfer to the cage; and 4. Gaming facility supervisor who supervised the credit transaction. I. The credit slip shall be inserted with the credit request duplicate in the drop box by the dealer. MICS 542.12(c)(18) J. 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. A computerized system may replace the manual fill or Credit process. TSC App. A:17(9) 1. 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 2. The system provides for adequate separation of duties within the system through passwords or other security features 3. If at any time the computerized system fails, the manual process will be followed until the computerized system returns to full capabilities B. 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) C. This documentation shall be restricted to authorized personnel. MICS 542.12(e)(2) D. 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) E. 7.9. The electronic system must include a personnel access listing, which includes, at a minimum: MICS 542.12(e)(3)(ii) 1. Employee name; 2. Employee identification number; and 3. Listing of functions employees can perform or equivalent means of identifying the same. Playing Cards and Dice Standards A. 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) B. 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) C. 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) D. 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) E. 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) A. Records shall be maintained, by day and shift, indicating any single-deck blackjack games that were dealt for an entire shift. B. 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. C. This information shall be presented to and reviewed by management independent of the pit department on at least a monthly basis. 1. Such management shall investigate any unusual fluctuations in hold percentage with pit supervisory personnel. 2. The results of such investigations shall be documented, maintained for inspection, and provided to TGA upon request. Chapter 8 8.1. System Overview A. 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 A. Jackpot Payouts and Accumulated Credit Payouts Standards for EGM/Player Terminal for jackpot payouts, documentation shall include the following information: 1. Date and time; (MICS 542.13(d)(i)) 2. Machine number; (MICS 542.13(d)(ii)) 3. 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)) 4. 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)) 5. Signatures of at least two employees verifying and witnessing the payout; 6. Preprinted or concurrently printed sequential number. (MICS 542.13(d)(v)) (MICS 542.13(d)(vi)) B. Surveillance is notified prior to initiation of payout procedures for jackpot awards equal to or greater than $10,000 C. 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) D. Computerized jackpot systems shall be restricted so as to prevent unauthorized access and fraudulent payouts by one individual. (MICS 542.13(d)(3)) E. 8.3. EGS Funds Standards A. 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 A. 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)) B. Game software media control standards. 1. C. 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)) 1. Receipt and destruction of game software media; (MICS 542.13(g)(2)(iv)) and 2. Securing the game software media, from unrestricted access. (MICS 3. Records, which document the above game software media procedures, shall include the following information: 542.13(g)(2)(v)) a) Date; (MICS 542.13(g)(5)(i)) b) Machine number (source and destination); (MICS 542.13(g)(5)(ii)) c) Manufacturer; (MICS 542.13(g)(5)(iii)) d) Program number; (MICS 542.13(g)(5)(iv)) e) Personnel involved; (MICS 542.13(g)(5)(v)) f) Disposition of any permanently removed game software media; g) Approved testing lab approval numbers, if available. (MICS (MICS 542.13(g)(5)(vii)) 542.13(g)(5)(ix)) 4. 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)) 5. 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) D. 8.5. EGS Player Tracking A. 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 A. Accurate and current theoretical hold worksheets shall be maintained for each Gaming Machine. (MICS 542.13(h)(1)) B. 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)) C. All of the Gaming Machines shall contain functioning meters which shall record credit-in. (MICS 542.13(h)(8)) D. 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)) E. 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)) F. 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)) G. 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)) H. 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)) I. 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)) J. 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)) K. 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)) L. 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)) M. 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)) N. 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)) O. 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)) P. 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. 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)) B. 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. C. Each gaming operation shall record the base amount of each progressive jackpot the gaming operation offers. (MICS 542.13(k)(4)) D. 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. 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)) B. 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)) C. The TGA shall approve procedures for the wide area progressive system that: (MICS 542.13(l)(3)) 1. Reconcile meters and jackpot payouts; 2. Collect/drop Gaming Machine funds; 3. Verify jackpot, payment, and billing to gaming operations on pro-rata basis; 4. System maintenance; 5. System accuracy; and 6. System security. 8.9. EGS Cash-Out Ticket Standards A. For EGS machines that accept currency (or tickets) and issue cash-out tickets, the following standards shall apply: 1. 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) 2. 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) 3. 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: a) Scan the bar code via an optical reader or its equivalent; or (MICS b) Input the cash-out ticket validation number into the computer. 542.13(n)(4)(i) (MICS 542.13(n)(4)(ii) 4. 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) 5. 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) 6. 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) 7. If invalid, the host computer shall notify the cashier that one of the following conditions exists: (MICS 542.13(n)(7) a) The serial number cannot be found on file (stale date, forgery, etc.); b) The cash-out ticket has already been paid; or c) The amount of the cash-out ticket differs from the amount on file. 8. 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) 9. If the host validation system temporarily goes down, cashiers may redeem cash-out tickets after recording the following: (MICS 542.13(n)(8) 10. a) Serial number of the cash-out ticket; b) Date and time; c) Dollar amount; d) Issuing EGM/Player Terminal number; e) Mark the ticket as “paid”; and f) 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) a) Mitigate the risk of counterfeiting of cash-out ticket paper; b) Adequately controls the inventory of the cash-out ticket paper; and c) 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 A. 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): A. 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) B. 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) C. 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) 1. 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) 2. 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) 3. 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) 4. 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 A. The following requirements shall be met in connection with any Cashless Transaction System: (TSC X2 8.1) B. All player information must be stored on at least two separate non-volatile media; (TSC X2 8.1.1) C. 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) D. Physical and operational controls must be used to protect player information from tampering or unauthorized access; (TSC X2 8.1.3) E. Passwords or personal identification numbers (PINs), if used, must be protected from unauthorized access; (TSC X2 8.1.4) F. All player information shall be accurately recorded and such recording protected by the system; (TSC X2 8.1.6) G. 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) H. 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: I. 1. Cash converted to value in the cashless system 2. Outstanding unredeemed balance: 3. Value in the cashless system converted to cash; 4. Amount wagered; and 5. 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) J. Vouchers must bear on the face, in addition to the unique serial number, the following: 1. Time/Date printed; 2. Unique identification from which it was printed; and 3. 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: A. Each Game Set shall be made up of a finite number of Electronic Scratch Tickets; B. 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; C. 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; D. Each Game Set shall be assigned a unique serial number; and E. 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. A. 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. A. 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. A. Each Electronic Scratch Ticket Game Subset shall meet the following minimum requirements: 1. 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; 2. 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; 3. 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. 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. A. 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) 1. A unique identifying Game Set serial number; (TSC X2 3.3.1) 2. A description of the Game Set theme sufficient to categorize the Game Set relative to other Game Sets; (TSC X2 3.3.2) 3. The number of total Scratch Tickets in the Game Set; (TSC X2 3.3.3) 4. 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) 5. The payout percentage of the entire Game Set; (TSC X2 3.3.5) 6. 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) 7. The purchase price per ticket assigned to the Game Set; (TSC X2 3.3.7) 8. 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. A. 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) 1. The Game Set and Game Subsets serial numbers; (TSC X2 3.4.1) 2. The total number of Electronic Scratch Tickets unsold, if the game is removed from play; (TSC X2 3.4.2) 3. The total number of Electronic Scratch Tickets purchased; (TSC X2 3.4.3) 4. The time and date that each Subset was transmitted to the Central Computer; (TSC X2 3.4.4) 5. The time and date that the game was completed or removed from play; 6. The final payout percentage of the game; and (TSC X2 3.4.6) 7. Price per Ticket. (TSC X2 3.4.7) (TSC X2 3.4.5) 8.20. TLS Software Auditing Tool to be Made Available. A. 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 A. 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) B. 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) C. 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) D. 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) A. 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) B. 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) C. 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) D. 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. A. The following requirements apply to any Central Computer used in connection with an Electronic Scratch Ticket Game. (TSC X2 3.8) 1. Dispensing of Tickets. The Central Computer shall dispense, upon request from a Player Terminal, Electronic Scratch Tickets. (TSC X2 3.8.1) 2. 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) 3. 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) 4. 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. A. 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) 1. 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) 2. 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. A. 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) B. Player Terminals shall include the following features: 1. 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) 2. 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) 3. C. 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) 1. 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) 2. Error conditions that may have occurred on the Player Terminal; and (TSC 3. Recall of the last twenty five (25) cash or cash equivalent deposits. (TSC X2 X2 5.3.3) 5.3.4) D. 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. E. 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) F. 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) 1. Credits, or equivalent monetary units, wagered on a cumulative basis on that Terminal; (TSC X2 5.6.1) 2. Credits, or equivalent monetary units, won for the Player Terminal; (TSC X2 3. For Scratch Ticket games, the number of Scratch Tickets purchased on the Terminal; and (TSC X2 5.6.3) 4. For On-line Lottery games, the number of On-line Lottery wagers made on that Terminal. (TSC X2 5.6.4) 5.6.2) G. 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) H. 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) 1. The rules of the game being played; (TSC X2 5.8.1) 2. 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) 3. The player's credit balance; (TSC X2 5.8.3) 4. The outcome of the Electronic Scratch Ticket(s) then being played; and (TSC X2 5.8.4) 5. Any prize won on the Electronic Scratch Ticket(s) then being played. (TSC X2 5.8.5) I. 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) J. 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) K. 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) L. 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) 1. Determines which Scratch Ticket outcome from within the Scratch Ticket Subset is transmitted to the Player Terminal; or (TSC X2 5.12.1) 2. Alters the amount of the payout of the Electronic Scratch Ticket as received from the Central Computer. (TSC X2 5.12.2) M. 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) N. 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. A. 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) 1. 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) 2. 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. A. 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) 1. 2. 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) a) Live network jacks shall be locked to prevent someone from removing the legitimate connection and plugging in an unauthorized device. b) 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) a) 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. b) 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. 3. 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) 4. 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) 5. 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) 6. 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) 7. 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) a) 8. 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) 9. 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 [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Acowlitz%3A7d83ff630f7c9157. Public record. Not legal advice.