Little Traverse Bay Bands of Odawa Indians (2011)

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Waganakising Odawak

Little Traverse Bay Bands of Odawa Indians

Office of Tribal Chairman

7500 Odawa Circle, Harbor Springs, Michigan 49740

Phone 231-242-1401 e Fax 231-242-1411

GAMING REGULATORY COMMISSION REGULATIONS

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SECTION I. PREAMBLE

A.

C.

Development of Regulations. The following regulations are issued pursuant to the

powers vested in the Gaming Regulatory Commission by the Gaming Regulatory

Ordinance enacted by the Tribal Council of the Little Traverse Bay Bands of Odawa

Indians on February 20, 2011 (Waganakising Odawa Statute 2011-005) and approved by

the National Indian Gaming Commission (“NIGC”) on April 1, 2011, or Waganakising

Odawak Statute 2011-005 upon approval of the NIGC. The Tribal Council reviewed and

approved these Regulations on

Policy. It is the declared policy of the Tribe that all of the Gaming Enterprises and

Gaming Operations subject to its jurisdiction be controlled through a comprehensive

system of licenses, non-key licenses, and other appropriate regulations so as to ensure

compliance with all applicable law and regulations governing the operation of the

Gaming Enterprises

Authority. These regulations are promulgated and adopted under the authority of

Waganakising Odawak Statute 2011-005 and replace any earlier regulations of the

Gaming Regulatory Commission.

SECTION Tf. DEFINITIONS

A.

D.

“Chairperson” means the chairperson of the Gaming Regulatory Commission chosen by

the members of the Commission under Section X (B) (2) of the Gaming Regulatory

Ordinance.

“Collateral Agreement” means any written contract that is related, either directly or

indirectly, to a management contract, or to any rights, duties or obligations created

between a tribe or any of its members, entities, or organizations.

“Executive” means the Executive Branch of the Little Traverse Bay Bands of Odawa

Indians pursuant to the Constitution of the Little Traverse Bay Bands of Odawa Indians

adopted February 1, 2005

“Facility” means any building where gaming is conducted including related hotel and

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restaurant services and ancillary enterprises and activities of the Tribe.

E. “Gambling game” or “game” or “gaming” means any game authorized by the LTBB

Gaming Regulatory Statute.

F. “Gaming Authority” is a Committee of Tribal Council and is delegated management

responsibilities as set forth in WOS 2010-021 or its successor.

G. “Gaming Enterprise” means any commercial enterprise of the Tribe authorized to engage

in Gaming, and all ancillary commercial activities within the building(s) and other

improvements constructed for the conduct of Gaming.

H. “Gaming Operations” means all operations directly related to the conduct of Gaming at

the facilities.

L “Gaming Regulatory Commission” or "Commission" means the Gaming Regulatory

Commission which is comprised of three to five appointed officials, assisted by regulatory

staff, to fulfill the duties required for regulation of the tribal gaming operations.

J, “Key Contractor/Gaming Vendor” means any person or other legal entity, other than a

primary management official or key employee, who has a contract with the Gaming

Operations where the contractor performs for the gaming operation any function

described in the definition of a key employee or primary management official, included

but not limited to all providers of Class II or Class III games of chance, gaming

equipment, supplies or services.

K. “Key employee” means:

1. A person who performs one or more of the following functions:

Bingo Caller

Counting Room Supervisor

Chief of Security

Custodian of gaming supplies or cash

Floor Manager

Pit Boss

Dealer

Croupier

Approver of Credit

Custodian of gambling devices including persons with access to cash and

accounting records within such devices; or

Custodians of confidential or proprietary information or records

Trg hoe pe op

~

2. If not otherwise included, any other person whose total cash compensation is in

excess of $50,000 per year; or

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3. If not otherwise included, the four most highly compensated persons in the

gaming operation.

4, Additionally, the Gaming Regulatory Commission may require a similar standard.

of review for employees who do not fall under the definition of key employee

whose position and access to money or records warrants such review.

L. “License” means a revocable privilege (including temporary licenses) granted for a

limited period of time by the Gaming Regulatory Commission, pursuant to these

Regulations, to a person or entity to perform certain acts.

M. “Management contract” means any contract, subcontract, or collateral agreement between

LTBB and a contractor or between a contractor and a subcontractor if such contract or

agreement provides for the management of all or part of a gaming operation.

N. “Management contractor” means any person or other legal entity having a direct or

indirect financial interest in a management contract. Provided, the Gaming Regulatory

Commission may in its discretion treat spouses of any such person as management

contractors where it is determined that such treatment is necessary to protect the interests

of the Tribe.

0. “National Indian Gaming Commission’ or “NIGC” means the federal gaming regulatory

body created by the Indian Gaming Regulatory Act (Public Law 100-497, 25 U.S.C. §§

2701 et seq.) “IGRA”).

P. “Non-key license” means a license issued to non-key employees under Section V.

Q. “Person having a direct/indirect financial interest in a management contract” means:

1. When a person is a party to a management contract, any person having a direct

financial interest in such management contract;

2. When a trust is a party to a management contract, any beneficiary or trustee;

3. When a partnership is a party to a management contract, any partner;

4. When a corporation is a party to a management contract, any person who is a

director or who holds at least 10% of the issued and outstanding stock alone or in

combination with another stockholder who is a spouse, parent, child or sibling; or

5. When an entity other than a natural person has an interest in a trust, partnership or

corporation that has an interest in a management contract, all parties of that entity

are deemed to be persons having a direct financial interest in a management

contract.

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W.

“Person having management responsibility for a management contract” means the person

designated by the management contract as having management responsibility for the

gaming operation, or a portion thereof.

“Player” means a person who participates in a game other than as an employee or

contractor of the gaming operation.

“Primary Management Official” means:

1. The person having management responsibility for a management contract;

2. Any person who has authority:

a. To hire and/or fire employees; or

b. To set up working policy for the gaming operation; or

3. The chief financial officer or other person who has financial management

responsibility over the Gaming Enterprise.

4. Any other person designated by the Gaming Regulatory Commission based on

level of signing authority or job position responsibilities.

“Regulatory” means the LTBB Gaming Regulatory Commission and or its staff.

“Regulatory Director” means the person employed by the Gaming Regulatory

Commission designated by the Regulatory Commission as having management

responsibility for the day to day operations of the Regulatory Departments.

“Standard employee” or “non-key employee” means any employee of a gaming operation

who works in any capacity except primary management officials and key employees.

Xx.

Z.

“Temporary License” means a revocable privilege granted for a limited period of time by

the Gaming Regulatory Commission, pursuant to these Regulations, to a person or entity

to perform certain acts that do not require separate approval from the federal government.

“Tribal Council” means the Legislative Branch of the Little Traverse Bay Bands of

Odawa Indians pursuant to the Constitution of the Little Traverse Bay Bands of Odawa

Indians, adopted February 1, 2005.

“Tribe” or “LTBB” means the Little Traverse Bay Bands of Odawa Indians.

SECTION IIL SURVEILLANCE SERVICES

The Surveillance Department shall be supervised by the General Manager of the

Enterprise. All Surveillance reports will be sent to the General Manager and Regulatory Director

or designee. In the event that a Surveillance report requires additional investigation by

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Regulatory the General Manager will not release the report until the investigation is

complete, When discussing changes to Surveillance Policies or Procedures, the Regulatory

Director shall be invited to participate.

Suspected Criminal Activity or cheating by any Licensee shall be immediately reported to

Regulatory.

SECTION IV. LICENSES

A. Revocable privilege.

1.

An application for a license constitutes a request to the Gaming Regulatory

Commission for a decision upon the applicant’s suitability, character, integrity,

and ability to participate or engage in, or be associated with, the gaming industry

in the manner or position sought by the applicant.

The burden of proving an applicant’s qualification to receive any license is at all

times on the applicant.

The granting of a license by the Gaming Regulatory Commission does not

constitute a commitment on behalf of the Gaming Regulatory Commission or any

other party or entity to hire or continue to employ the licensee.

These regulations do not apply to bona fide traditional Indian gambling games, so

long as such games are conducted by Indian persons or organizations at Tribal

celebrations or gatherings and not as a business.

B. License categories.

1.

Facility license. No gambling games may be played at any place, facility, or

location within the Tribe’s jurisdiction unless the manager or designee of the

gaming operation first obtains and thereafter maintains in good standing a valid

facility license issued in accordance with these regulations.

Management contractor’s license. No person, corporation or other entity other

than the Tribe may serve as the management contractor for a Tribally owned

gaming operation within the Tribe’s jurisdiction unless said management

contractor first obtains and thereafter maintains in good standing a valid

management contractor’s license issued in accordance with these regulations.

Primary management official’s license. No person, corporation, or other entity

other than the Tribe may have a management interest, or financial interest in the

profits of a gaming operation unless she/he first obtains and thereafter maintains

in good standing a valid primary management official’s license issued in

accordance with these regulations.

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Key employee license. No person shall be employed as a Key Employee by the

Gaming Enterprise or by the Gaming Regulatory Commission unless such person

first obtains and thereafter maintains in good standing a valid key employee

license issued in accordance with these regulations.

Non-key license. Each non-key employee in a gaming operation shall first obtain

and maintain in good standing a valid non-key license issued in accordance with

Section V of these regulations.

Key contractor/Gaming Vendor license. No person or other legal entity shall

enter into any contract with the Gaming Operation that establishes the entity as a

key contractor unless the entity first obtains and thereafter maintains in good

standing a valid key contractor/gaming vendor license issued in accordance with

these regulations.

C. Standards for issuance of a license. No key or primary management official license may

be issued to any applicant who:

Is under the age of 18;

Has been convicted of, or entered a plea of guilty or no contest to, a gambling

related offense, fraud or misrepresentation. The terms "fraud or

misrepresentation," as used in this subsection shall mean a criminal offense

committed in Michigan or any other jurisdiction, involving, theft, fraud or

misrepresentation, which is a felony or would be a felony if committed in

Michigan, and which was committed as an adult or prosecuted as an adult offense,

and which has not been effectively removed from the applicant's criminal record

by executive pardon, state court order, or operation of law;

Has been convicted of, or entered a plea of guilty or no contest to, any offense not

specified in subparagraph (2) within the immediately preceding five years; this

provision shall not apply if the applicant has been pardoned by the Governor of

the State where the conviction occurred or, if a Tribal Citizen, has been

determined by the Gaming Regulatory Commission to be a person who is not

likely again to engage in any offensive or criminal course of conduct and the

public good does not require that the applicant be denied a license as a key

employee or primary management official;

a. The term "any offense," as used in this subsection (C)(3), shall mean any

criminal offense not described in subsection (C)(2), whether committed in

this state or any other jurisdiction, that is, or would be, a crime under the

provisions of the Michigan Penal Code, Act No. 328 of the Public Acts of

1931, as amended, being MCL 750.1 to 750.568, or the controlled

substance provisions of the Public Health Code, Act No. 368 of the Public

Acts of 1978, as amended, being MCL 333.7101 to 333.7545, or any other

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criminal offense not specified in subparagraph (2) involving theft,

dishonesty, fraud or misrepresentation arising under the law of Michigan

or another state or jurisdiction, that was committed as an adult or

prosecuted as an adult offense, and which has not been effectively

removed from the applicant’s criminal record by executive pardon, state

court order, or operation of law.

Is determined by the Gaming Regulatory Commission to have participated in

organized crime or unlawful gambling or whose prior activities, criminal records,

reputation, habits, and/or associations pose a threat to the public interest or to the

effective regulation and control of gaming, or create or enhance the dangers of

unsuitable, unfair, or illegal practices, methods and activities in the conduct of

gaming or to the carrying on of the business and financial arrangements incidental

to the conduct of gaming;

Has knowingly and willfully provided materially false statements or fails to

disclose (verbally or in writing) information to the Gaming Regulatory

Commission or its licensing department or refused to respond to questions asked

him/her by the Gaming Regulatory Commission;

Has any outstanding warrant for arrest from any jurisdiction;

Does not meet the federal requirements pertaining to Indian gaming licenses,

especially the IGRA and related regulations;

Has been convicted of, or entered a plea of guilty or no contest to, a misdemeanor

or felony sex offense. The term "sex offense,"-as used in this subsection shall

mean a criminal offense committed in Michigan or any other jurisdiction, which

is a misdemeanor or felony or would be a misdemeanor or felony if committed in

Michigan, and which was committed as an adult or prosecuted as an adult offense,

and which has not been effectively removed from the applicant’s criminal record

by executive pardon, state court order, or operation of law.

A licensing decision will not be made while charges for offenses found in section

2 and 3 are pending;

D. License application procedures.

1.

General requirements, Applicants for a gaming license must complete the

appropriate application form and submit the form, along with all necessary

additional documents to the Gaming Regulatory Commission. The application

will not be regarded as complete until all requested information has been

received from the applicant.

Application forms; contents; amendments.

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a. Every application or report must be filed on forms furnished or approved

by the Gaming Regulatory Commission and must contain and be

accompanied by such documents and information as may be specified

thereon or otherwise required.

db. All information required to be included in an application must be true and

complete as of the date submitted to the Gaming Regulatory Commission,

and an applicant shall have a continuing duty to promptly inform the

Gaming Regulatory Commission of any material factual change or any

new information occurring after the original application. Failure by an

applicant to promptly update his/her application to include all material

facts shall be deemed by the Gaming Regulatory Commission as a failure

to disclose.

c. Every application for any gaming license, other than a facility license,

shall include, at a minimum, the following information:

i. Full name, other names used (oral or written), social security

number(s), birth date, place of birth, citizenship, gender, all

languages (spoken or written);

il. Currently and for the previous 5 years: business and employment

positions held, ownership interests in those businesses, business

and residence addresses, and driver’s license numbers;

iii. The names and current addresses of at least three personal

references, including one personal reference who was acquainted

with the applicant during each period of residence listed under

paragraph (c)(ii) of this section;

iv. Current business and personal telephone numbers;

v. A description of any existing and previous business relationships

with Indian tribes, including ownership interests in those

businesses;

vi. A description of any existing and previous business relationships

with the gaming industry generally, including ownership interests

in those businesses;

vii. The name and address of any licensing or regulatory agency with

which the person has filed an application for a license or permit

related to gaming, whether or not such license or permit was

granted;

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viii.

ix.

xi.

xii.

xiii.

xiv.

For each felony for which there is an ongoing prosecution or a

conviction, the charge, the name and address of the court involved,

and the date and disposition if any;

For each misdemeanor conviction or ongoing misdemeanor

prosecution (excluding minor traffic violations) within 10 years of

the date of the application, the name and address of the court

involved and the date and disposition;

For each criminal charge (excluding minor traffic charges) whether

or not there is a conviction, if such criminal charge is within 10

years of the date of the application and is not otherwise listed

pursuant to paragraph (viii) or (ix) of this subsection, the criminal

charge, the name and address of the court involved and the date

and disposition;

The name and address of any licensing or regulatory agency with

which the person has filed an application for an occupational

license or permit, whether or not such license or permit was

granted;

A photograph;

Any other information the Gaming Regulatory Commission deems

relevant; and

Fingerprints consistent with procedures adopted by the Tribe.

The Gaming Regulatory Commission may license only those facilities

owned by the Tribe and operated by the Tribe itself or by the Tribe in

conjunction with a management contractor pursuant to a management

agreement approved by the NIGC. Every application for a facility license

shall include, at minimum, the following information;

ii.

iii.

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The name, address, and telephone number of the Gaming

Operation;

The name, address, and telephone number of the management

company, if any, and the name, address, social security number,

birth date, and percentage interest in the management company of

each person possessing a financial interest in excess of 5% in the

management company;

An operating plan containing at a minimum the details specified in

Section [V(L)(2) of these Regulations;

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iv. A list of all primary management officials, including the position

and annual salary of each individual listed; and

v. The complete current or proposed house rules of the gaming

operation.

An application may only be amended after submission to Licensing with

the consent and solely at the discretion of the Gaming Regulatory

Commission or designee at any time prior to the Gaming Regulatory

Commission’s final action on the application.

Any document filed under any of the provisions of the Gaming Regulatory

Ordinance or these regulations may be incorporated by reference in a

subsequent application if the document is available in the files of the

Gaming Regulatory Commission, to the extent that the document is

currently accurate.

Fingerprints. An application for a primary management official or key employee

license shall not be complete until the applicants fingerprints are taken by the

Gaming Regulatory Commission or Tribal Police Department.

Application and investigation fees.

Non-refundable application fees as periodically set by the Gaming

Regulatory Commission and approved by Tribal Council must be paid by

the applicant or the Gaming Enterprise under section 4.d.

In addition to any non-refundable application fees paid, the Gaming

Regulatory Commission may require an applicant to pay such

supplementary investigative fees and costs as may be determined by the

Gaming Regulatory Commission. The Gaming Regulatory Commission

may estimate the supplementary investigative fees and costs and may

require the applicant to pay the estimated fees and costs in advance as a

condition precedent to beginning or continuing an investigation.

The Gaming Regulatory Commission may not act upon any application

unless all application and investigation fees and costs have been paid in

full. The Gaming Regulatory Commission shall deny an application if the

applicant has failed or refused to pay all application and investigation fees

and costs.

The Gaming Regulatory Commission may take preliminary or final action

on an application before the required application and investigation fees are

received only if payment of the fees is guaranteed by an agreement with

the Gaming Enterprise.

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In the case of a management contract, the application fee will be the actual

cost of processing the application for a management contractor, including

’ the cost of background investigations. A management contractor shall pay

a $50,000.00 deposit with the application. After the application is

processed, the Gaming Regulatory Commission shall either refund any

portion of the deposit not needed to cover processing expenses, or bill the

management contractor for any processing costs in excess of the deposit

amount.

E. Background investigations.

1. Within 14 Calendar days after receipt of a complete application and such

supplemental information as the Gaming Regulatory Commission may require,

the licensing staff shall begin its investigation of the applicant’s background to

determine if the applicant meets the Gaming Regulatory Commission’s minimum

license standards. The licensing staff shall investigate the criminal history of each

applicant for a license and the personal background, character, reputation and

associations of each applicant for a license, and may make such inquiries of

and/or about said associations as may be necessary to form a conclusion about the

applicant’s eligibility for a license. At a minimum, the following investigations

shall be performed before taking preliminary or final action on any application:

a.

Applicant for any gaming license. The criminal background of an

applicant for any gaming license shall be investigated by submitting the

applicant’s vital information, including but not limited to: full name; any

other names used, date and place of birth; citizenship, driver’s license

numbers; social security number; and physical description to the Michigan

State Police and/or local law enforcement agencies, and to the Federal

Bureau of Investigation Criminal Information Center, and to any other law

enforcement agencies that the Gaming Regulatory Commission deems

appropriate, requesting a criminal history report. Any fingerprints of

applicants required to be taken under these regulations shall also be

submitted to these law enforcement agencies.

Applicant for any gaming license - additional requirements. If the

applicant lived outside the United States for more than six months during

the preceding eight years, the Gaming Regulatory Commission shall also

utilizethe applicant’s vital information to searchinternational databases for

any criminal history. The Gaming Regulatory Commission shall also

interview at least three previous employers, associates, or other persons

familiar with the applicant to determine if the applicant’s reputation,

character, habits, and activities meet the standards for issuance of a

license. The Gaming Regulatory Commission shall also obtain a credit

bureau report on the applicant, and shall take such other steps as it may

deem reasonable to verify the information provided by the applicant.

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c. Applicant for a primary management official’s license. In addition to

other investigations, the Gaming Regulatory Commission shall contact

banks, other financial institutions, and other information sources as needed

to verify the accuracy of financial information provided by each person in

an application for a primary management official’s license.

The Gaming Regulatory Commission is not limited to the above investigations

and shall make additional investigations and inquiries as required by federal law

or regulation or as needed to determine with reasonable certainty that an applicant

either does or does not meet the minimum standards for issuance of a gaming

license. Such investigation may include personal interviews with applicants.

The Gaming Regulatory Commission shall attempt to complete its background

investigation within 60 days following receipt of a complete application. If the

investigation cannot be completed within 60 days after receipt of a complete

application, the Gaming Regulatory Commission shall notify the applicant in

writing why the investigation is not complete and when it expects to complete the

investigation.

The Gaming Regulatory Commission may contract with private, state, and/or

federal investigation agencies to perform the required background and/or criminal

history investigations when necessary.

F. Application reviews; approvals; denials; waivers.

1.

Review. Within 14 calendar days following completion of the background

investigation the Gaming Regulatory Commission shall review each applicant and

all background investigation and criminal history reports to determine if the

applicant meets the standards for issuance of the requested license.

License approval.

a. Preliminary approval; temporary licenses. If, in the Gaming Regulatory

Commission’s judgment, the applicant meets the standards for issuance of

a license and all application and investigation fees are fully paid, the

Gaming Regulatory Commission may grant its preliminary approval of the

application. At its discretion, the Gaming Regulatory Commission may

also issue a temporary or conditional license. A temporary license is valid

for 90 days.

b. National Indian Gaming Commission review. Within seven (7) days after

granting preliminary approval of a license application, the Gaming

Regulatory Commission shall send the results of the background

investigation per the NIGC requirements. The Gaming Regulatory

Commission shall also include a cover letter indicating the Gaming

Regulatory Commission’s intent to issue the applicant a license and

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request that the federal agency review the application pursuant to the

requirements of federal law. A copy of this letter may also be sent to the

applicant with a notice that the application is not finally approved.

Final approval. The Gaming Regulatory Commission may grant final

approval of a license application only after:

i. Receiving notice from the NIGC that it has no objection to the

issuance of the license; or

ii. 30 days have elapsed since the NIGC was notified of the Gaming

Regulatory Commission’s intent to issue the license and the NIGC

has not responded; or

ili. The NIGC timely objected to the issuance of the license, the

Commission has reconsidered the application, taking into account

the NIGC’s objections and the Commission has determined that

the applicant may be licensed notwithstanding those objections.

The Gaming Regulatory Commission shall promptly notify each approved

applicant that his/her application is approved and issue a license. If a temporary license

was previously issued, the effective date of the license shall be the issue date of the

temporary license.

3.

License limitations and restrictions. No license shall be valid unless signed by a

majority of the Gaming Regulatory Commission members. The Gaming

Regulatory Commission may limit the term of the license, or place such

conditions thereon as it may deem necessary to protect the Tribe or public

interest.

The Gaming Regulatory Commission shall deny an application for any

class of license if, in the Gaming Regulatory Commission’s opinion, the

applicant does not meet the standards required for issuance of the

requested license under these regulations and applicable law. The Gaming

Regulatory Commission has the discretion to deny any application or to

revoke a license, if, in the Gaming Regulatory Commission’s judgment,

such a denial or revocation is in the best interest of the Tribe.

The Gaming Regulatory Commission may deny an application at any time

during the application process, including after granting preliminary

approval to the application.

The Gaming Regulatory Commission shall promptly notify an applicant

that his/her application was denied and shall specify the reasons for the

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denial, including a list of criminal conviction(s), date(s), and location(s), if

any, that contributed to the Gaming Regulatory Commission’s decision to

deny the application. If an application was denied as a result of

information contained in the applicant’s FBI identification record, the

applicant shall be advised of the procedures to change, correct, or update

the record as set forth in Title 28 CFR, Section 16.34.

Waivers. Any enrolled LTBB Tribal Citizendenied a license may request a

waiver of the license standards, only to the extent allowed under Section IV

(C)@3) pursuant to the hearing provisions set out in Section VII of these

regulations. Waivers will not be considered for any non-LTBB member. The

eligible LTBB Tribal Citizen must show that a waiver is in the best interests of

the Tribe or the Gaming Regulatory Commission may not grant the requested.

waiver.

G. Expirations.

1.

Except for a facility license, management contractor’s license or a key

contractor/gaming vendor license, the expiration date of each license shall be

determined by the licensee’s anniversary date. The license shall expire on the

licensee’s next anniversary date.

A key contractor/gaming vendor or management contractor’s license shall expire

not later than one year from the date it was issued.

A facility license shall expire not later than threeyears from the date it was issued.

The expiration schedules in this section describe the maximum period for which a

license may be granted. The Gaming Regulatory Commission may issue any

license for a shorter period if the Gaming Regulatory Commission deems the

shorter period is necessary to adequately protect the interests of the Tribe or the

public.

Employment of expired licensed persons prohibited. The Gaming Operation shall

not allow any person or contractor to work if that person does not possess the

proper and valid license as required by these regulations. It shall be the

discretion of the gaming operation’s General Manager on whether or not the

licensee receives wages or benefits

H. Renewals. Subject to the power of the Gaming Regulatory Commission to deny, revoke,

suspend, or limit licenses, any gaming license in force may be renewed for the next year

with payment of applicable license and investigation fees as required by law and the

regulations of the Gaming Regulatory Commission. The Gaming Regulatory

Commission shall encourage license holders to apply for a license renewal at least 60

days prior to expiration of the current license, but the Gaming Regulatory Commission

may not accept a renewal application more than 120 days prior to expiration of the

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current license.

L Issuance of License Identification Cards.

1.

The Gaming Regulatory Commission shall issue a license identification card to

every person granted a license. The identification card shall include the licensee’s

photograph, name, license number, name of the gaming operation by which they

are employed or to which they provide services, expiration date of the license,

logo, and such other identifying marks deemed necessary by the Gaming

Regulatory Commission to readily identify legitimate cards from counterfeit

cards. The licensing staff shall issue identification cards pursuant to procedures

established by the Gaming Regulatory Commission. A temporary license

identification card may not be issued until the applicant’s application has been

approved by the licensing department. The license is no longer temporary when

signed by the majority of the Gaming Regulatory Commission.

Every licensee shall at all times while on duty wear their license identification

card issued by the Gaming Regulatory Commission. Gaming Regulatory

Commission employees or off duty licensees are not required to wear their

identification card, however, are required to carry it with them at all times and are

required to promptly show their identification card to any person requesting to

inspect the card.

a. The Gaming Regulatory Commission may consider a waiver for this

requirement upon receipt of a written request from the Gaming Operation

General Manager for special events.

Each licensee shall be required to surrender their photo identification card when:

the card expires; a new license is issued; the licensce’s association with the

gaming operation ends, whether or not the termination is voluntary; or the license

is suspended or revoked.

Any person who has lost their photo identification card must report the loss to the

licensing staff within 24 hours of the loss or discovery of the loss. Replacement

of a lost photo identification card may be made for a fee as approved by the

Gaming Regulatory Commission.

For any licensee that works the gaming floor or with the general public the license

identification card must be displayed in a consistent manner with the exception of

waivers approved under 2. a.

J. Employment of unlicensed persons prohibited. The Gaming Operation shall not employ

any person or enter into any contract or agreement for services with any person in a

capacity for which that person is required to obtain a license if that person does not

possess the proper and valid license as required by these regulations. The gaming

operation shall immediately discharge any employee and cancel any contract or

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agreement upon notification by the Gaming Regulatory Commission that the employee’s

or contractor’ s/vendor’s license has been revoked by the Gaming Regulatory

Commission or that the employee or contractor/vendor does not possess the required

license.

K. Background review for hiring. Employees of the Gaming Enterprise who make hiring

determinations may review the background information, to the extent allowed by

applicable law and regulation, compiled by the Gaming Regulatory Commission for

applicants who have been issued a license.

L. Facility license requirements.

1.

License fees. The Tribal Government may require and set a facility licensing fee

to cover or help offset the actual expenses incurred by the Gaming Regulatory

Commission in carrying out its licensing and compliance functions.

Operating plan.

a.

Every facility licensee shall at all times maintain on file with the Gaming

Regulatory Commission a current operating plan, verified by the affidavit

of the operation’s general manager, including, but not limited to: days and

hours of operation; the maximum number and type of gaming tables or

devices expected to be uncovered or in use at any time during the year; the

number of gaming tables or devices expected to be in actual use during the

first month of the report year. The approved operating budget shall be

submitted to the Gaming Regulatory Commission within one week of its

approval by the operation’s manager but not later than two weeks prior to

the beginning of the operation’s new fiscal year.

Any significant changes (up or down) to the operating plan shall be

reported to the Gaming Regulatory Commission in writing no more than

two weeks following the end of the month in which the change occurred.

Significant changes include, but are not limited to: a change of 15% or

more in the number of gaming tables or devices uncovered or in use; a

change of 15% or more in the net profit forecast for the balance of the

current year; or a change in the operation’s fiscal year or accounting

policies.

Key employee report.

a.

Each facility licensee shall submit an annual key employee report to the

Gaming Regulatory Commission on a form to be furnished by the Gaming

Regulatory Commission.

The annua! key employee report shall identify every primary management

official and key employee of the operation and their annual wage or salary

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compensation. The report shall also include an organization chart for the

operation and a description of each primary management official’s and

key employee’s duties and responsibilities, and the authority delegated to

each individual identified in the report.

Any changes, additions, or deletions to any information contained within

the annual key employee report which occurs subsequent to the filing of

the report and prior to the filing of the next year’s report shall be reported

to the Gaming Regulatory Commission in writing no more than two weeks

following the month during which the change, addition, or deletion

occurred.

Financial Reports. A copy of the final annual audit report shall be submitted to

the Gaming Regulatory Commission by the Gaming Enterprise within three (3)

days of when the annual audit report is received by the Gaming Enterprise. This

report is required to be received no later than one-hundred-twenty (120) days

from the end of the fiscal year from the person responsible for preparing such

report under the Tribe’s law, regulations, and contracts.

Environmental, Public Health, and Safety CEPHS) Certification

a.

The Gaming Regulatory Commission shall receive a document listing all

laws, resolutions, codes, policies, standards, and procedures identified as

applicable to the gaming facility in :

° Emergency Preparedness

° Food and Potable Water

e Construction and Maintenance

° Hazardous Materials

° Sanitation

° Any other applicable areas related to environmental or public

health and safety standards adopted by the Tribe.

The Gaming Regulatory Commission is required to receive Annual

Certification that the gaming facility complies with and enforces the

identified laws, resolutions, codes, policies, standards, and procedures.

The annual certification requirements listed in a. and b. must be completed

by the LTBB Tribal Government.

The annual certification must be obtained byt the Gaming Operation and

submitted to the Gaming Regulatory Commission.

Purpose. The Gaming Regulatory Commission is required to receive the reports

and information specified in subsections 1., 2.,3., 4., and 5., to ensure that the

gaming operation is in compliance with Environmental, Public Health, and Safety

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standards established by the Tribal Government, to ensure that the gaming

operation is free of corruption and to aid in planning staffing and budgeting for

Regulatory Departments. The Gaming Regulatory Commission is not responsible

for, and shall not interfere with, any business decisions of the Gaming Enterprise.

M. Posting of facility license. A facility license by the Gaming Regulatory Commission

must be prominently displayed at all times upon the licensed premises in such position as

it may be observed by persons participating in the gaming activities.

N. Notice to patrons. In each facility of the Tribe where Class I1I Gaming is conducted the

Tribe shall post in a prominent position a Notice to Patrons at least two (2) feet by three

(3) feet in dimension with the following language:

NOTICE

THIS FACILITY IS REGULATED BY ONE OR MORE OF THE FOLLOWING:

THE NATIONAL INDIAN GAMING COMMISSION, BUREAU OF INDIAN AFFAIRS

OF THE U. S. DEPARTMENT OF THE INTERIOR AND THE GOVERNMENT OF

THE LITTLE TRAVERSE BAY BANDS OF ODAWA INDIANS

THIS FACILITY IS NOT REGULATED BY THE STATE OF MICHIGAN

SECTION V. NON-KEY LICENSE

A. Non-key licenses required. All non-key employees must obtain and maintain in good

standing a non-key license issued by the Gaming Regulatory Commission as set out in

this section. A non-key employee cannot be employed in key employee position without

first obtaining a license under Section IV of these Regulations. The application contents

and procedures for a non-key license are the same as those for a license under Section IV,

except information on non-key employees need not be sent to the NIGC or made

available to the State of Michigan, and the investigation need only include criminal

history checks

B. Issuance standards. The Gaming Regulatory Commission shall not issue a non-key

license to any applicant under any of the following:

1. The applicant is under the age of eighteen, with the exception of applicants in

approved work programs in non-gaming floor areas of the Enterprise;

2. The applicant has knowingly and willfully provided materially false statements or

fails to disclose (verbally or in writing) information to the Gaming Regulatory

Commission or its licensing department or refused to respond to questions asked.

him/her by the Gaming Regulatory Commission;

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3. The applicant has knowingly and willfully provided materially false statements to

the Gaming Regulatory Commission or Regulatory staff or refused to cooperate

with Gaming Regulatory staff conducting an investigation;

The applicant has been convicted in the past ten years of any felony involving

theft, fraud or violence. Provided, this provision shall not apply ifthe applicant

has been pardoned by the Governor of the State where the conviction occurred or,

if a Tribal Citizen, has been determined by the Gaming Regulatory Commission

to be a person who is not likely again to engage in any offensive or criminal

course of conduct and the public good does not require that the applicant be

denied a non-key license; or

The applicant is determined by the Gaming Regulatory Commission, based on

criminal history checks, to pose a threat to the safety or security of the Enterprise

or persons present in the facilities.

C. A non-key license may be suspended or revoked if the applicant does not meet the

standards required for issuance of a non-key license.

SECTION VI. PENALTIES

A. Suspensions.

1.

Emergency suspensions. If, in the Regulatory Director’s or Licensing Manager’s

judgment, the licensee’s actions pose a threat to the integrity of the gaming

operation, the safety of the general public, patrons, or other employees, or the

image and reputation of the Tribe, the Gaming Regulatory Commission’s

Regulatory Director, Licensing Manager or their designees may seize an

individual’s identification card and exclude that individual from the gaming

establishment for up to 72 hours. The Gaming Regulatory Commission or its

designated staff shall inmmediately notify the gaming operation’s General

Manager of the emergency suspension. At its discretion, the Gaming Regulatory

Commission may take formal suspension action against the individual. The

gaming operation’s General Manager, attheir discretion, may or may not pay the

employee or contractor any wages, benefits, or other compensation except for

legitimate services actually rendered prior to the suspension.

Formal suspension.

a. The Regulatory Director or Licensing Manager may issue a Notice

suspending a license if there is reasonable cause to believe that:

i. The suspension is necessary for the immediate preservation of the

public peace, health, safety, morals, good order, or general welfare

of the Tribe;

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ii. The licensee may have violated any condition or requirement

imposed on the licensee by the Gaming Regulatory Commission or

applicable laws;

iti. The licensee has been convicted of a criminal offense related to

gambling, theft, fraud;

iv. There is clear evidence that the licensee is involved in activities

that occurred during the course of employment that if convicted

would impact the licensee’s ability to be licensed;

v. The licensee has knowingly and willfully provided materially false

statements to the Gaming Regulatory Commission or Regulatory

staff or has refused to cooperate with Gaming Regulatory staff

conducting an investigation.

The suspension Notice becomes effective when it is signed by the

Regulatory Director or Licensing Manager and the holder of the license

receives actual or constructive notice of the order.

The Notice issued by the Regulatory Director or Licensing Manager is a

suspension pending a revocation hearing before the Gaming Regulatory

Commission. The suspension Notice suspending the license must state the

reason for the suspension, and shall advise the licensee of the time limit

for requesting an appeal hearing.

The suspension Notice shall state that the licensee shall forfeit his/her

right to a hearing and any appeal if s/he fails properly to request a hearing

before the Gaming Regulatory Commission within 30 days following

effective date of the Notice.

By the end of the next business day following the effective suspension

date of a license, the Regulatory Director or Licensing Manager shall

notify the General Manager of the gaming operation employing or

contracting services of the suspended license(s) of the suspension. The

gaming operation’s General Manager shall immediately suspend the

employee or contractor/vendor and shall not pay the employee or

contractor/vendor any wages, benefits, or other compensation except for

legitimate services actually rendered prior to the suspension.

n the event that the suspension is overturned by the Commission, it shall

be at the discretion of the gaming operation’s general manager on

whether or not the suspended employee or contractor receives any

wages, benefits, or other compensation that would have been paid

during the period of suspension.

it. In the event that the Commission suspends an employee’s

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or contractor’s license for a set period of time and such period of time is

less than the actual time that the employee or contractor was suspended,

then it shall be at the discretion of the gaming operation’s General

Manager on whether or not to compensate the employee or contractor any

wages, benefits, or other compensation during the period not included in

the suspension as set by the Commission.

f. If the suspension involves the license of theGeneral Managerr or the

facility, the Regulatory Director or Licensing Manager shall notify the

management contractor or other representative of the operation’s owner.

g. The Gaming Regulatory Commission may suspend a license for any

period of time up to one year in length.

h. The Gaming Regulatory Commission, Regulatory Director or Licensing

Manager may reinstate a license only after the licensee resolves to the

Gaming Regulatory Commission’s satisfaction the cause for making the

suspension.

B. Civil Penalties. The Gaming Regulatory Commission may issue citations against any

Licensee for any violation of the Gaming Regulatory Statute, these Regulations and

MICS, or any applicable Tribal or Federal law or regulation, or provisions of the

Compact. The Commission may adopt a schedule of fines and/or forfeitures as a

recommendation for sanctions that may be imposed by the Court upon receipt of an

admission of guilt or plea of no contest for violations committed. This schedule shall not

apply as to penalties assessed by the Court after adjudicating a violation where the

defendant has entered a plea of not guilty. No citations for fines shall be issued against a

facility license of the Enterprise that would violate any covenant in an existing agreement

between the Tribe or Enterprise, and lenders. (See Addendum 1)

Cc. Criminal Prosecution. The Gaming Regulatory Commission shall promptly submit any

knowledge or evidence of criminal wrongdoing that it may discover to the appropriate

law enforcement official for prosecution.

D. Revocations. In addition to any penalty the Gaming Regulatory Commission may elect

to impose against a licensee, the Gaming Regulatory Commission may revoke any

gaming license if the Gaming Regulatory Commission determines that the licensee:

1.

2.

No longer meets the minimum standards or requirements for issuance of a license;

Failed to disclose, misstated, or otherwise misled the Gaming Regulatory

Commission about any fact contained within any application for a license;

Violated any of the terms or conditions under which the Gaming Regulatory

Commission granted the license;

The licensee has been convicted of a criminal offense related to gambling, theft,

fraud, or for activities that occur during employment.

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5. The licensee has knowingly and willfully provided materially false statements to

the Gaming Regulatory Commission or Regulatory staff or refused to cooperate

with Gaming Regulatory staff conducting an investigation; or

6. The licensee failed to request a hearing before the Gaming Regulatory

Commission to reinstate a suspended license within 30 days.

7. Any person or other legal entity who has had a license revoked by the Gaming

Regulatory Commission shall not be eligible to apply for a new license for a

period of ten (10) years after the effective date of the revocation.

SECTION VI. APPEALS AND HEARING PROCEDURES (Denials, Suspensions

and Revocations)

A. Applicability

These Hearing Procedures apply to Licensees under the jurisdiction of the Gaming Regulatory

Commission (hereafter referred to as "Commission") and shall be used in all Licensing Hearings

conducted by the Commission.

B. Fair Hearings

The Commission is comprised of appointed officials with delegated authority under Tribal and

Federal law to promulgate regulations for the Little Traverse Bay Bands Gaming Enterprise(s).

The Commission shall make every effort to take affirmative steps to provide fair and objective

hearings.

C. Roles and Responsibilities

The Commission shall serve in the capacity of "hearing officers", of which one shall serve as the

"Presiding Officer.” The Regulatory Director or his /her delegate shall serve in the capacity of

"Petitioner," whose responsibility is to provide facts and arguments relating to the licensing

matter. "Licensee" refers to applicants, employees, vendors and facilities and includes both key

and non-key licenses. Together, Petitioner and Licensee are referred to as the "Parties." The

Commission reserves the right to designate and assign duties to the Gaming Regulatory Director

and/or Gaming Regulatory Administrative Assistant.

D. Service of a Notice to Deny, Suspend or Revoke a License

Notices and other hearing documents that deny, suspend or revoke a license shall be served upon

the Licensee by personal service or by United States mail. Ifthe notice is served by mail, it shall

be addressed to the Licensee's last known address. It is the Licensees' duty to keep the

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Commission's designee informed of current address.

E. Rights of Licensee

The Licensee whose license is denied, suspended, or revoked:

1. Has the right to a hearing before the Gaming Regulatory Commission on the

Gaming Regulatory staffs Notice of Denial, Suspension or Revocation..

2. Must file a written notice of appeal request to the Gaming Regulatory

Commission for a hearing within 30 days following the effective date of the

Gaming Regulatory staffs Notice of Denial, Suspension, or Revocation as stated

on the Notice. Failure to properly request a hearing in within 30 days waives the

person’s right to a hearing or any other appeal of the Gaming Regulatory

Commission’s or staffs Notice of Denial, Suspension, or Revocation.

F, Timing of Hearing

After receipt of a written request for an appeal, the Gaming Regulatory Commission shall

schedule a hearing not later than 21 calendar days after receipt of the request unless the

Commission and the person requesting the appeal mutually agree to an extension. Following the

hearing the Gaming Regulatory Commission shall make a decision to uphold, modify, or reverse

the staff's Notice imposing the license denial, suspension or revocation.

G. Prohibition of Ex Parte Communication

In an effort to assure a fair hearing process, unless required for the disposition of ex parte matters

authorized by law or by the Commission:

L .Comumnissioners shall not communicate, directly or indirectly with any party or

their representative in connection with any issue of fact or law related to a hearing

except upon notice and opportunity to all parties to participate;

2. This section shall not preclude Gaming Regulatory staff from having contact with

a Licensee at any stage of the proceedings.

H. Appearance through an Advocate

Parties to proceedings governed by this regulation may appear personally or through an advocate

(i.e. attorney, tribal member, friend, etc.). [fa party appears through an advocate, the party must

attend hearings unless excused by the Commission. Parties retaining an advocate who requires a

fee shall retain the advocate at their own cost.

1. When a party has appeared through an attorney, service of notices of hearings,

decisions or any other matters shall thereafter be made upon the attorney.

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2. When a party has appeared through a non-attorney advocate, service of all notices

of hearings, decisions or any other matters shall thereafter be made upon the

Licensee, who assumes the responsibility of sharing information with the

advocate.

3. The Commission reserves the right to directly question the Licensee during the

hearing.

L Discovery and Mandated Exchanges

Prior to the hearing the parties shall exchange all evidence they intend to introduce, and shall

also exchange written lists of all persons each party intends to call as a witness. Each witness

shall be identified by name, with a brief description of the reason for which the witness will be

called. Failure to disclose evidence and witness lists prior to the hearing may limit a party's

opportunity to introduce evidence.

J. Confidential and Privileged Materials

If any document or other material required to be produced is the subject of a privilege or is

confidential under applicable law or is subject to a confidentiality agreement, the document shall

be marked "confidential" before disclosure or use in a hearing. A Licensee shall not further

disseminate confidential or privileged materials except to counsel/advocate of record in the

action.

K. Request for Information

Either party may make a written request to the Commission for its assistance in obtaining

relevant documents, witnesses and other evidence within the Commission's jurisdiction.

Information requests must be specific and contain type of evidence and date of occurrence.

Determinations regarding relevancy, admissibility, and confidentiality shall be in the

Commission's sole discretion.

L. Limitations

If any party or their attorney/advocate fails reasonably to comply with these regulations, or any

order entered regarding any matter, including discovery, the Commission may impose upon such

party, advocate, or attorney, or both, appropriate limitations including an order prohibiting the

use of any witness or evidence which should have been disclosed, produced, exhibited, or

exchanged.

M. Conduct of Hearings

The hearing before the Commission will proceed as follows:

1. Opening comments and questions.

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a. Presiding Officer

b. Petitioner

c. Licensee

2. Case Presentation

a. Petitioner

b. Licensee

3. Rebuttals

a. Petitioner

b. Licensee

4. Commission/Hearing Officer’s Questions.

5. Closing Argument

a. Petitioner

b. Licensee

N. Evidence

The Commission shall consider evidence that it finds relevant and material to the hearing, giving

the evidence such weight as is appropriate. The Commission may limit testimony to exclude

evidence that would be immaterial or unduly repetitive. Upon request before the hearing, the

Commission in its discretion may permit the introduction of additional previously undisclosed

evidence.

oO. Failure to Testify

If a party fails to testify in their own behalf or asserts a claim of privilege in response to any

question, the Commission may infer that such testimony or answer would have been adverse to

Licensee's case. Licensee may rebut such inference with an explanation based on a legitimate

legally binding reason, such as a confidentiality agreement.

P. Continuances

Continuances will not be granted except for good cause shown.

Q. Default

Failure of a Licensee to appear personally at the hearing, unless otherwise excused by the

Commission, shall constitute admission of all matters and facts. A judgment by default shall be

rendered against an unexcused Licensee and the Commission may take action against the gaming

license without further notices to the Licensee.

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R. Decision of the Commission

At the conclusion of the hearing the Commission may;

1. Reinstate the license;

2. Reinstate the license with conditions or limitations;

3. Modify the suspension for a period of time up to one year in length; or

4. Revoke the license.

The Commission's decision shall be in writing and shall be based upon a preponderance of the

evidence standard (the offense or other cause for the suspension, revocation, denial or penalty

more likely than not occurred). Written notice of the decision shall be sent to the parties.

S. Tribal Court Review

1.

Following a final decision of the Gaming Regulatory Commission after a hearing

under this Section, a Licensee has a right to file an appeal with the LTBB Tribal

Court. The burden of proof in the appeal process is on the applicant or Licensee.

All appeals shall be in writing. A Licensee shall have 20 calendar days from the

date of receiving the hearing decision of the Gaming Regulatory Commission to

file an appeal in writing with the Tribal Court.

The sole purpose of the Tribal Court appeal will be to determine if the

Commission made a procedural error that significantly prejudiced the Licensee. In

the event the Tribal Court determines such error was made, it shall remand to the

Gaming Regulatory Commission to hold a new hearing in accordance with these

Regulations.

SECTION VIII. GAMING OPERATIONS

A. Gaming Equipment.

1.

No Class Hl or Class II games of chance, equipment or supplies may be operated,

purchased, leased or otherwise acquired by the Tribe unless the equipment or

supplies meet the technical standards of either: the State of Nevada, State of New

Jersey or the State of Michigan.

The seller, lessor, manufacturer, or distributor shall provide, assemble and install

all Class III or Class Il games of chance, gaming equipment, and supplies in a

manner approved and licensed by the Tribe.

B. Gaming Prohibitions.

1.

No employee or member of the Gaming Regulatory Commission, and no Member

of the Gaming Authority Committee shall be permitted to participate as a player

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in any game operated within the Facility.

Gaming operations employees, except those employed in the Surveillance

Department, may participate as players in any game operated within the Facility

while off-duty provided that the employee is not directly involved in operating or

maintaining such game in the course of their work. By way of example, slot

attendants shali not play slot machines, and table games managers or dealers shall

not play table games. Employees on the gaming floor while not on duty shall not

openly display their license, but must have their license on their person and

accessible for review upon request by Gaming Regulatory staff, management or

security or other such designated individuals.

Members of the Tribal Council, the Tribal Chair, Vice-Chair and members of the

Judiciary may participate as players in any game operated within the Facility, but

shall not receive complimentary rewards.

Surveillance Department employees shall be barred from participating as players

in any game operated within the facility for a period of one (1) year after their

employment terminates, whether the termination of the employment relationship

was voluntary or involuntary, unless waiver is approved by the Gaming

Regulatory Commission.

Gaming operations employees and Tribal officials listed in subsections 2 and 3

are not eligible for promotions, incentives or awards related to gaming activity,

including but not limited to vehicle drawings, players club cards and earning

points.

Employees of Gaming Vendors licensed by the LTBB Gaming Regulatory

Commission are not permitted to participate in any game operated in the Facility.

Gifts may only be accepted by a Licensee in accordance with policies approved

by the Gaming Regulatory Commission.

C. Credit Prohibited. No credit shall be extended by a gaming operation to any player. This

prohibition shall not be construed, however, to prevent players or customers from

utilizing bank cards, credit cards, and other forms of personal credit when the credit is

guaranteed or extended by an independent financial institution.

D. Age Requirements.

1.

At the Facility located at 1760 Lears Road, Petoskey, Michigan, no individual

under nineteen (19) years of age may play any game in the Enterprise, nor shall

any such person be allowed to loiter or remain in the immediate area in which any

such game is being played, provided that individual is not an employee of the

Enterprise.

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2. In the event that LTBB opens a second class IM gaming site in accordance with

the 2003 Amendment to the Compact Between LTBB and the State of Michigan,

no individual under twenty one (21) years of age may play any game in such

second Enterprise site, nor shall any such person be allowed to loiter or remain in

the immediate area in which any such game is being played, provided that

individual is not an employee of the Enterprise.

SECTION IX. DISPUTE RESOLUTION

Disputes between the gaming public and the Tribe or management official shall be

resolved as follows:

A. The complaining member of the gaming public shall first have an opportunity to present

his/her grievance, verbally or in writing, to the general manager of the Gaming enterprise

or a person designated by the general manager to resolve grievances with members of the

gaming public.

B. If the grievance is not resolved under Section A. the complaining member of the general

public may file a written grievance with the Gaming Regulatory Commission. The

Gaming Regulatory Commission shall prepare and make available grievance forms that

include space for the name, address, and phone number of the grievant, and a description

of the situation or incident complained of. The Gaming Regulatory Commission or

designee shall review the written grievance within seven (7) days of receipt and shall

investigate the incident. If the Gaming Regulatory Commission deems it necessary, it

may hold a fact finding hearing to question the grievance and any employees of the

facility involved in the grievance. The Gaming Regulatory Commission shall take final

action on the grievance within thirty (30) days of receipt which may include any action.

authorized under the Gaming Regulatory Ordinance and these regulations.

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CERTIFICATION

As Chairperson, I certify that I approve these Gaming Regulatory Commission Regulations.

Date: ab- 9-15 <> eee Kaaca 2 stag

ReginaGasco -Bentley, Tribal Chair

Received by the Tribal Council Office on: ¢ YY a, i a

As the Legislative Leader and Tribal Council Secretary, we certify that these Gaming Regulatory

Commission Regulations were approved by the Tribal Council of the Little Traverse Bay Bands

of Odawa Indians at a regular meeting of the Tribal Council held on Lp. ult ZO/ES at

which a quorum was present, by a vote of in favor, opposed, (© abstentions, and

Van absent.

Date: 4B. BUS DYE title §- Lo ea

Mafcella Reye be iT

Date: 4-9. 16 yb N 2

lig Shananaquet , Secreti

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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