##### § 543.31   What are the minimum internal control standards for drop and count for Tier B gaming operations?

\(a\) *Computer applications.* For any computer applications utilized,
alternate documentation and/or procedures that provide at least the
level of control described by the standards in this section, as approved
by the Tribal gaming regulatory authority in writing, will be
acceptable.

\(b\) *Card game drop standards.* (1) The setting out of empty card game
drop boxes and the drop shall be a continuous process. The drop begins
with the removal of the first card game drop box; however, empty drop
boxes are not required to be placed on tables that are inactive at the
time of the drop.

2\) At the end of each shift:

\(i\) All locked card game drop boxes shall be removed from the tables
by a person independent of the card game shift being dropped;

\(ii\) A separate drop box shall be placed on each table opened at any
time during each shift or a gaming operation may utilize a single drop
box with separate openings and compartments for each shift; and

\(iii\) Upon removal from the tables, card game drop boxes shall be
transported directly to the count room or other equivalently secure area
with comparable controls and locked in a secure manner until the count
takes place.

\(3\) If drop boxes are not placed on all tables, then the card game
department shall document which tables were open during the shift.

\(4\) The transporting of card game drop boxes shall be performed by a
minimum of two persons, at least one of whom is independent of the card
game shift being dropped.

\(5\) All card game drop boxes shall be posted with a number
corresponding to a permanent number on the gaming table and marked to
indicate game, table number, and shift.

\(6\) Surveillance shall be notified when the drop is to begin so that
surveillance may monitor the activities.

\(c\) *Soft count room personnel.* (1) The card game soft count and the
player interface financial instrument storage component count shall be
performed by a minimum of two persons.

\(2\) Count room personnel shall not be allowed to exit or enter the
count room during the count except for emergencies or scheduled breaks.
At no time during the count, shall there be fewer than two individuals
in the count room until the drop proceeds have been accepted into
cage/vault accountability. Surveillance shall be notified whenever count
room personnel exit or enter the count room during the count.

\(3\) Count team members shall be rotated on a routine basis such that
the count team is not consistently the same two persons more than four
(4) days per week. This standard shall not apply to gaming operations
that utilize a count team of more than two persons.

\(4\) The count team shall be independent of transactions being reviewed
and counted. The count team shall be independent of the cage/vault
departments, however, a dealer or a cage cashier may be used if this
person is not allowed to perform the recording function. An accounting
representative may be used if there is an independent audit of all soft
count documentation.

\(5\) All coin, tokens, chips and/or cash inventory stored in the count
room shall be secured from unauthorized access at all times.

\(d\) *Card game soft count standards.* (1) The card game soft count
shall be performed in a soft count room or other equivalently secure
area with comparable controls.

\(2\) Access to the count room during the count shall be restricted to
members of the drop and count teams, with the exception of authorized
observers, supervisors for resolution of problems, and authorized
maintenance personnel.

\(3\) If counts from various revenue centers occur simultaneously in the
count room, procedures shall be in effect that prevent the commingling
of funds from different revenue centers.

\(4\) The card game drop boxes shall be individually emptied and counted
in such a manner to prevent the commingling of funds between boxes until
the count of the box has been recorded.

\(i\) The count of each box shall be recorded in ink or other permanent
form of recordation.

\(ii\) For counts that do not utilize a currency counter, a second count
shall be performed by a member of the count team who did not perform the
initial count. Separate counts of chips and tokens must always be
performed by members of the count team.

\(5\) Card game drop boxes, when empty, shall be shown to another member
of the count team, or to another person who is observing the count, or
to surveillance, provided the count is monitored in its entirety by a
person independent of the count.

\(6\) Corrections to information originally recorded by the count team
on soft count documentation shall be made by drawing a single line
through the error, writing the correct figure above the original figure,
and then obtaining the initials of at least two count team members who
verified the change.

\(7\) The count sheet shall be reconciled to the total drop by a count
team member who shall not function as the sole recorder and variances
shall be reconciled and documented.

\(8\) All members of the count team shall sign the count document or a
summary report to attest to their participation in the count.

\(9\) All drop proceeds and cash equivalents that were counted shall be
turned over to the cage or vault cashier (who shall be independent of
the count team) or to an authorized person/agent independent of the
revenue generation and the count process for verification. Such person
shall certify by signature as to the accuracy of the drop proceeds
delivered and received. Any variance shall be reconciled and documented.

\(10\) The count sheet, with all supporting documents, shall be
delivered to the accounting department by a count team member or a
person independent of the cashiers department. Alternatively, it may be
adequately secured (e.g., locked container to which only accounting
personnel can gain access) until retrieved by the accounting department.

\(11\) The cage/vault person shall sign the count sheet, or other
reconciling document, and thereby assume accountability of the currency
drop proceeds, ending the count.

\(12\) Access to stored, full card game drop boxes shall be restricted
to authorized members of the drop and count teams.

\(e\) *Player interface bill acceptor drop standards.* (1) A minimum of
two persons shall be involved in the removal of the player interface
drop, at least one of whom is independent of the bingo department.

\(2\) All financial instrument storage components shall be removed only
at the time previously designated by the gaming operation and reported
to the Tribal gaming regulatory authority, except for emergency drops.

\(3\) Surveillance shall be notified when the drop is to begin so that
surveillance may monitor the activities. The player interface storage
component drop begins when the first storage component is removed.

\(4\) The financial instrument storage components shall be removed by a
person of the bingo department then transported directly to the count
room or other equivalently secure area with comparable controls and
locked in a secure manner until the count takes place.

\(i\) Security shall be provided over the financial instrument storage
components removed from the player interface and awaiting transport to
the count room.

\(ii\) The transporting of financial instrument storage components shall
be performed by a minimum of two persons, at least one of whom is
independent of the bingo department.

\(5\) All financial instrument storage components shall be posted with a
number corresponding to a permanent number on the player interface.

\(f\) *Player interface bill acceptor count standards.* (1) The player
interface financial instrument storage component count shall be
performed in a soft count room or other equivalently secure area with
comparable controls.

\(2\) Access to the count room during the count shall be restricted to
members of the drop and count teams, with the exception of authorized
observers, supervisors for resolution of problems, and authorized
maintenance personnel.

\(3\) If counts from various revenue centers occur simultaneously in the
count room, procedures shall be in effect that prevent the commingling
of funds from different revenue centers.

\(4\) The count team shall not have access to bill-in meter amounts
until after the count is completed and the drop proceeds are accepted
into the cage/vault accountability. A count team member is allowed to
read/record the amount from the bill-in meters provided the count team
members do not have knowledge of the dollar amount of currency contained
in the financial instrument storage components pursuant to the bill-in
meters during the count process.

\(5\) Immediately prior to the count at least two count team members
shall verify the accuracy of the currency counter with previously
counted currency for each denomination (i.e., test currency). The test
currency is counted by the currency counter to ensure the counter is
functioning properly. The test results shall be documented and
maintained.

\(i\) The currency counter test must be performed with test currency
rather than with currency from a bill acceptor.

\(ii\) If the same currency counter is used for one revenue center
(e.g., gaming or nongaming revenue center) and then immediately used for
a second revenue center, performing the currency counter test once will
satisfy the standard provided the same count team members complete one
count and then proceed to the other revenue center count.

\(6\) If a currency counter interface is used:

\(i\) It shall be adequately restricted (e.g., password, keys, etc.) so
as to prevent unauthorized access.

\(ii\) The currency drop figures shall be transferred via direct
communications line or computer storage media to the accounting
department.

\(7\) Unannounced currency counter and currency counter interface (if
applicable) tests shall be performed by personnel independent of the
cage, vault, count team and bingo departments on at least a quarterly
basis with the test results being documented and maintained. All
denominations of currency and all types of cash-out tickets counted by
the currency counter must be tested. This test may be performed by
internal audit. The result of these tests shall be documented and signed
by the person or persons performing the test.

\(8\) The financial instrument storage components shall be individually
emptied and counted in such a manner to prevent the commingling of funds
between storage components until the count of the storage component has
been recorded.

\(i\) The count of each storage component shall be recorded in ink or
other permanent form of recordation.

\(9\) If currency counters are utilized and the count room table is used
only to empty storage components and sort/stack contents, a count team
member shall be able to observe the loading and unloading of all
currency at the currency counter, including rejected currency. The count
team member operating the currency counter does not need to be monitored
by another count team member if an individual independent of the count
process monitors the operator of the currency counter on an unannounced
basis for a minimum of one hour during the count process from recorded
or live surveillance at least monthly. The date, time, and results of
the independent observation shall be documented.

\(10\) When the currency counter rejects currency but does not record
the amount of rejected currency, procedures shall be developed and
implemented to record the rejected currency amount, by player interface,
and to ensure that two counts of the rejected currency (by player
interface and in total) are performed to ensure the correct amount of
the drop is recorded on the count sheet. Posting rejected currency to a
nonexistent "dummy" player interface is prohibited.

\(11\) Storage components, when empty, shall be shown to another member
of the count team, to another person who is observing the count, or to
surveillance, provided that the count is monitored in its entirety by a
person independent of the count.

\(12\) To correct errors in soft count documentation, a single line
shall be drawn through the error, and the correct figure entered above
the original figure. The correction shall be initialed by at least the
two count team members verifying the change. If a currency interface is
used, corrections to player interface count data shall be made using
either of the following:

\(i\) Draw a single line through the error on the player interface
document and write the correct figure above the original figure. The
correction shall then be initialed by two count team members, verifying
the change. If this procedure is used, an individual independent of the
bingo department and count team shall enter the correct figure into the
computer system prior to the generation of related bingo reports; or

\(ii\) During the count process, correct the error in the computer
system and enter the passwords of at least two count team members. If
this procedure is used, an exception report shall be generated by the
computer system identifying the player interface number, the error, the
correction, and the count team members attesting to the correction.

\(13\) The count sheet shall be reconciled to the total drop by a count
team member who shall not function as the sole recorder, and variances
shall be reconciled and documented. This standard does not apply to
vouchers removed from the financial instrument storage component.

\(14\) All members of the count team shall sign the count document or a
summary report to attest to their participation in the count.

\(15\) All drop proceeds and cash equivalents that were counted shall be
turned over to the cage or vault cashier (who shall be independent of
the count team) or to an authorized person independent of the revenue
generation and the count process for verification. Such person shall
certify by signature as to the amount of the drop proceeds delivered and
received. It is recommended that the individual performing the
verification count be precluded from having prior knowledge of the
results of previous count performed by count team personnel. Any
unresolved variances shall be reconciled, documented, and/or
investigated by accounting/revenue audit.

\(16\) The cage/vault person shall sign the count sheet, or other
reconciling document, and thereby assume accountability of the currency
drop proceeds, ending the count.

\(17\) The count sheet, with all supporting documents, shall be
delivered to the accounting department by a count team member or a
person independent of the cashiers department. Alternatively, it may be
adequately secured (e.g., locked container to which only accounting
personnel can gain access) until retrieved by the accounting department.

\(18\) Access to stored financial instrument storage components, full or
empty, shall be restricted to:

\(i\) Authorized members of the drop and count teams; and

\(ii\) Authorized personnel in an emergency for the resolution of a
problem.

\(g\) *Player interface coin drop standards.* (1) A minimum of two
individuals shall be involved in the removal of the player interface
drop, at least one of whom is independent of the bingo department.

\(2\) All drop buckets shall be removed only at the time previously
designated by the gaming operation and reported to the Tribal gaming
regulatory authority, except for emergency drops.

\(3\) Surveillance shall be notified when the drop is to begin in order
that surveillance may monitor the activities. The player interface coin
drop begins when the first drop bucket is removed.

\(4\) Security shall be provided over the buckets removed from the
player interface drop cabinets and awaiting transport to the count room.

\(5\) As each player interface is opened, the contents shall be tagged
with its respective player interface number if the bucket is not
permanently marked with the player interface number. The contents shall
be transported directly to the area designated for the counting of such
drop proceeds. If more than one trip is required to remove the contents
of the player interfaces, the filled carts of coins shall be securely
locked in the room designed for counting or in another equivalently
secure area with comparable controls. There shall be a locked covering
on any carts in which the drop route includes passage out of doors.

\(i\) Alternatively, a smart bucket system that electronically
identifies and tracks the player interface number, and facilitates the
proper recognition of gaming revenue, shall satisfy the requirements of
this paragraph.

\(ii\) \[Reserved\]

\(6\) Each drop bucket in use shall be:

\(i\) Housed in a locked compartment separate from any other compartment
of the player interface and keyed differently than other player
interface compartments; and

\(ii\) Identifiable to the player interface from which it is removed. If
the player interface is identified with a removable tag that is placed
in the bucket, the tag shall be placed on top of the bucket when it is
collected.

\(7\) Each player interface shall have drop buckets into which coins or
tokens that are retained by the player interface are collected. Drop
bucket contents shall not be used to make change or pay hand-paid
payouts.

\(8\) The collection procedures may include procedures for dropping
player interfaces that have trays instead of drop buckets.

\(h\) *Hard count room personnel.* (1) The weigh/count shall be
performed by a minimum of two individuals.

\(2\) At no time during the weigh/count shall there be fewer than two
individuals in the count room until the drop proceeds have been accepted
into cage/vault accountability. Surveillance shall be notified whenever
count room personnel exit or enter the count room during the count.

\(i\) If the player interface count is conducted with a continuous
mechanical count meter that is not reset during the count and is
verified in writing by at least two individuals at the start and end of
each denomination count, then one individual may perform the wrap.

\(ii\) \[Reserved\]

\(3\) Count team members shall be rotated on a routine basis such that
the count team is not consistently the same two persons more than four
(4) days per week. This standard shall not apply to gaming operations
that utilize a count team of more than two persons.

\(4\) The count team shall be independent of transactions being reviewed
and counted. The count team shall be independent of the cage/vault
departments, unless they are non-supervisory bingo personnel and perform
the laborer function only (Non-supervisory bingo personnel are defined
as persons below the level of bingo shift supervisor). A cage cashier
may be used if this person is not allowed to perform the recording
function. An accounting representative may be used if there is an
independent audit of all count documentation.

\(i\) *Player interface coin count and wrap standards.* (1) Coins shall
include tokens.

\(2\) The player interface coin count and wrap shall be performed in a
count room or other equivalently secure area with comparable controls.

\(i\) Alternatively, an on-the-floor drop system utilizing a mobile
scale shall satisfy the requirements of this paragraph, subject to the
following conditions:

\(A\) The gaming operation shall utilize and maintain an effective
on-line player interface monitoring system, as described in
§542.13(m)(3);

\(B\) Components of the on-the-floor drop system shall include, but not
be limited to, a weigh scale, a laptop computer through which
weigh/count applications are operated, a security camera available for
the mobile scale system, and a VCR to be housed within the video
compartment of the mobile scale. The system may include a mule cart used
for mobile weigh scale system locomotion.

\(C\) The gaming operation must obtain the security camera available
with the system, and this camera must be added in such a way as to
eliminate tampering.

\(D\) Prior to the drop, the drop/count team shall ensure the scale
batteries are charged;

\(E\) Prior to the drop, a videotape shall be inserted into the VCR used
to record the drop in conjunction with the security camera system and
the VCR shall be activated;

\(F\) The weigh scale test shall be performed prior to removing the unit
from the hard count room for the start of the weigh/drop/count;

\(G\) Surveillance shall be notified when the weigh/drop/count begins
and shall be capable of monitoring the entire process;

\(H\) An observer independent of the weigh/drop/count teams (independent
observer) shall remain by the weigh scale at all times and shall observe
the entire weigh/drop/count process;

\(I\) Physical custody of the key(s) needed to access the laptop and
video compartment shall require the involvement of two persons, one of
whom is independent of the drop and count team;

\(J\) The mule key (if applicable), the laptop and video compartment
keys, and the remote control for the VCR shall be maintained by a
department independent of the bingo department. The appropriate
personnel shall sign out these keys;

\(K\) A person independent of the weigh/drop/count teams shall be
required to accompany these keys while they are checked out, and observe
each time the laptop compartment is opened;

\(L\) The laptop access panel shall not be opened outside the hard count
room, except in instances when the laptop must be rebooted as a result
of a crash, lock up, or other situation requiring immediate corrective
action;

\(M\) User access to the system shall be limited to those persons
required to have full or limited access to complete the
weigh/drop/count; and

\(N\) When the weigh/drop/count is completed, the independent observer
shall access the laptop compartment, end the recording session, eject
the videotape, and deliver the videotape to surveillance.

\(ii\) \[Reserved\]

\(3\) Access to the count room during the count shall be restricted to
members of the drop and count teams, with the exception of authorized
observers, supervisors for resolution of problems, and authorized
maintenance personnel.

\(4\) If counts from various revenue centers occur simultaneously in the
count room, procedures shall be in effect that prevent the commingling
of funds from different revenue centers.

\(5\) The following functions shall be performed in the counting of the
player interface drop:

\(i\) Recorder function, which involves the recording of the player
interface count; and

\(ii\) Count team supervisor function, which involves the control of the
player interface weigh and wrap process. The supervisor shall not
perform the initial recording of the weigh/count unless a weigh scale
with a printer is used.

\(6\) The player interface drop shall be counted, wrapped, and
reconciled in such a manner to prevent the commingling of player
interface drop coin with coin (for each denomination) from the next
player interface drop until the count of the player interface drop has
been recorded. If the coins are not wrapped immediately after being
weighed or counted, they shall be secured and not commingled with other
coin.

\(i\) The amount of the player interface drop from each player interface
shall be recorded in ink or other permanent form of recordation on a
player interface count document by the recorder or mechanically printed
by the weigh scale. Additionally, if a weigh scale interface is used,
the count figures shall be transferred via direct communications line or
computer storage media to the accounting department.

\(ii\) Corrections to information originally recorded by the count team
on player interface count documentation shall be made by drawing a
single line through the error, writing the correct figure above the
original figure, and then obtaining the initials of at least two count
team members who verified the change.

\(A\) If a weigh scale interface is used, corrections to player
interface count data shall be made using either of the following:

( *1* ) Drawing a single line through the error on the player interface
document, writing the correct figure above the original figure, and then
obtaining the initials of at least two count team members. If this
procedure is used, an individual independent of the bingo department and
count team shall enter the correct figure into the computer system prior
to the generation of related player interface reports; or

( *2* ) During the count process, correct the error in the computer
system and enter the passwords of at least two count team members. If
this procedure is used, an exception report shall be generated by the
computer system identifying the player interface number, the error, the
correction, and the count team members attesting to the correction.

\(B\) \[Reserved\]

\(7\) If applicable, the weight shall be converted to dollar amounts
before the reconciliation of the weigh to the wrap.

\(8\) If a coin meter is used, a count team member shall convert the
coin count for each denomination into dollars and shall enter the
results on a summary sheet.

\(9\) The recorder and at least one other count team member shall sign
the weigh tape and the player interface count document attesting to the
accuracy of the weigh/count.

\(10\) All members of the count team shall sign the count document or a
summary report to attest to their participation in the count.

\(11\) All drop proceeds and cash equivalents that were counted shall be
turned over to the cage or vault cashier (who shall be independent of
the count team) or to an authorized person independent of the revenue
generation and the count process for verification. Such person shall
certify by signature as to the accuracy of the drop proceeds delivered
and received.

\(12\) All player interface count and wrap documentation, including any
applicable computer storage media, shall be delivered to the accounting
department by a count team member or a person independent of the
cashier\'s department. Alternatively, it may be adequately secured
(e.g., locked container to which only accounting personnel can gain
access) until retrieved by the accounting department.

\(13\) If the coins are transported off the property, a second
(alternative) count procedure shall be performed before the coins leave
the property. Any variances shall be documented.

\(14\) Variances. Large (by denomination, either \$1,000 or 2% of the
drop, whichever is less) or unusual (e.g., zero for weigh/count or
patterned for all counts) variances between the weigh/count and wrap
shall be investigated by management personnel independent of the bingo
department, count team, and the cage/vault functions on a timely basis.
The results of such investigation shall be documented, maintained for
inspection, and provided to the Tribal gaming regulatory authority upon
request.

\(j\) *Security of the coin room inventory during the player interface
coin count and wrap.* (1) If the count room serves as a coin room and
coin room inventory is not secured so as to preclude access by the count
team, then the following standards shall apply:

\(i\) At the commencement of the player interface count the following
requirements shall be met:

\(A\) The coin room inventory shall be counted by at least two persons,
one of whom is a member of the count team and the other is independent
of the weigh/count and wrap procedures;

\(B\) The count in paragraph (j)(1)(i)(A) of this section shall be
recorded on an appropriate inventory form;

\(ii\) Upon completion of the wrap of the player interface drop:

\(A\) At least two members of the count team (wrap team), independently
from each other, shall count the ending coin room inventory;

\(B\) The counts in paragraph (j)(1)(ii)(A) of this section shall be
recorded on a summary report(s) that evidences the calculation of the
final wrap by subtracting the beginning inventory from the sum of the
ending inventory and transfers in and out of the coin room;

\(C\) Prior to verification of the count by cage/vault personnel, the
same count team members shall compare the calculated wrap to the
weigh/count, recording the comparison and noting any variances on the
summary report;

\(D\) A member of the cage/vault department shall count the ending coin
room inventory by denomination and shall reconcile it to the beginning
inventory, wrap, transfers and weigh/count. Any reconciliation variance
is documented; and

\(E\) At the conclusion of the reconciliation, at least two count/wrap
team members and the verifying cage/vault person shall sign the summary
report(s) attesting to its accuracy.

\(iii\) The functions described in paragraph (j)(1)(ii)(A) and (C) of
this section may be performed by only one count team member. That count
team member must then sign the summary report, along with the verifying
cage/vault person, as required under paragraph (j)(1)(ii)(E).

\(2\) If the count room is segregated from the coin room, or if the coin
room is used as a count room and the coin room inventory is secured to
preclude access by the count team, all of the following requirements
shall be completed, at the conclusion of the count:

\(i\) At least two members of the count/wrap team shall count the final
wrapped player interface drop independently from each other;

\(ii\) The final counts, in total and by denomination, shall be recorded
on a summary report;

\(iii\) The same count team members (or the accounting department) shall
compare the final wrap to the weigh/count, recording the comparison, and
noting any variances on the summary report;

\(iv\) A member of the cage/vault department shall count the wrapped
player interface drop by denomination and reconcile it to the
weigh/count summary report. Any variance shall be reconciled and
documented;

\(v\) At the conclusion of the reconciliation, at least two count team
members and the cage/vault person shall sign the summary report
attesting to its accuracy; and

\(vi\) The wrapped coins (exclusive of proper transfers) shall be
transported to the cage, vault or coin vault after the reconciliation of
the weigh/count to the wrap.

\(vii\) The count team shall not have access to coin drop meter amounts
until after the count is completed and the drop proceeds have been
accepted into the cage/vault accountability. A count team member is
allowed to read/record the amount from the coin-in meters provided the
count team members do not have knowledge of the dollar amount of coin
contained in the drop buckets pursuant to the coin-in meters during the
count process.

\(k\) *Transfers of currency and coin during the count.* (1) Transfers
may be permitted during the count and wrap only if permitted under the
internal control standards approved by the Tribal gaming regulatory
authority.

\(2\) Each transfer shall be recorded on a separate multi-part form with
a preprinted or concurrently-printed form number that shall be
subsequently reconciled by the accounting department.

\(3\) Each transfer must be counted and signed for by at least two
members of the count team and by a person independent of the count team
who is responsible for authorizing the transfer.

\(4\) At least one part of the transfer form remains in the count room
until the drop has been accepted into cage/vault accountability. The
other part of the transfer form accompanies the funds transferred from
the count room during the count.

\(l\) *Key controls-general* (1) The player interface coin drop cabinet
keys, card games drop box release keys, financial instrument storage
component release keys, card games drop box content keys, financial
instrument storage component content keys, and kiosk keys shall all be
separately keyed from each other.

\(2\) Surveillance monitoring key access does not satisfy the
requirements in this part for physical involvement.

\(3\) All duplicate keys shall be maintained in a manner that provides
the same degree of control as is required for the original keys. Records
shall be maintained for each key duplicated that indicate the number of
keys made and destroyed.

\(4\) Records shall be maintained by the custodian of sensitive keys to
document authorization of personnel accessing keys.

\(m\) *Player interface drop key control standards.* (1) Player
interface coin drop cabinet keys, including duplicates, shall be
maintained by a department independent of the bingo department.

\(2\) The physical custody of the keys needed to access player interface
coin drop cabinets, including duplicates, shall require the involvement
of two persons, one of whom is independent of the bingo department.

\(3\) Two persons (separate from key custodian) shall be required to
accompany such keys while checked out and observe each time player
interface drop cabinets are accessed.

\(n\) *Card game drop box key control standards* (1) At least two count
team members are required to be present at the time count room and other
count keys are issued for the count.

\(o\) *Card game drop box release keys.* (1) The card game drop box
release keys shall be maintained by a department independent of the card
game department.

\(2\) Only the person(s) authorized to remove card game drop boxes from
the tables shall be allowed access to the card game drop box release
keys; however, the count team members may have access to the release
keys during the soft count in order to reset the card game drop boxes.

\(3\) Persons authorized to remove the card game drop boxes shall be
precluded from having simultaneous access to the card game drop box
contents keys and release keys.

\(4\) For situations requiring access to a card game drop box at a time
other than the scheduled drop, the date, time, and signature of the
person signing out/in the release key must be documented.

\(p\) *Financial instrument storage component release keys*. (1) The
financial instrument storage component release keys shall be maintained
by a department independent of the bingo department.

\(2\) Only the person(s) authorized to remove financial instrument
storage components from the player interfaces shall be allowed access to
the release keys.

\(3\) Persons authorized to remove the financial instrument storage
components shall be precluded from having simultaneous access to the
financial instrument storage components contents keys and release keys.

\(4\) For situations requiring access to a financial instrument storage
component at a time other than the scheduled drop, the date, time, and
signature of the person signing out/in the release key must be
documented.

\(q\) *Card game drop box storage rack keys.* Persons authorized to
obtain card game drop box storage rack keys shall be precluded from
having simultaneous access to card game drop box contents keys with the
exception of the count team.

\(r\) *Financial instrument storage component* *storage rack keys.*
Persons authorized to obtain financial instrument storage component
storage rack keys shall be precluded from having simultaneous access to
financial instrument storage component contents keys with the exception
of the count team.

\(s\) *Card game drop box contents keys.* (1) Issuance of the card game
drop box contents key at other than scheduled count times shall require
the involvement of at least three persons from separate departments,
including management. The reason for issuance shall be documented with
the signatures of all participants and observers. Two persons from
separate departments are required to accompany the card game drop box
contents key from the time the keys are issued until the time the keys
are returned. Note: The key custodian checking out keys constitutes
physical involvement. A computerized key security system functions as
the key custodian.

\(2\) Only count team members shall be allowed access to card game drop
box content keys during the count process.

\(t\) *Financial instrument storage component contents keys*. (1)
Issuance of the bill storage component contents key at other than
scheduled count times shall require the involvement of at least three
persons from separate departments, including management. The reason for
issuance shall be documented with the signatures of all participants and
observers. Two persons from separate departments are required to
accompany the financial instrument storage component contents key from
the time the keys are issued until the time the keys are returned. Note:
The key custodian checking out keys constitutes physical involvement. A
computerized key security system functions as the key custodian.

\(2\) Only the count team members shall be allowed access to financial
instrument storage component contents keys during the count process.

\(u\) *Player interface computerized key security systems.* (1)
Computerized key security systems which restrict access to the player
interface drop and count keys through the use of passwords, keys or
other means, other than a key custodian, must provide the same degree of
control as indicated in the aforementioned key control standards; refer
to paragraphs (m), (p), (r) and (t) of this section. Note: This standard
does not apply to the system administrator. The system administrator is
defined in paragraph (u) (2) (i) of this section.

\(2\) For computerized key security systems, the following additional
player interface key control procedures apply:

\(i\) Management personnel independent of the bingo department assign
and control user access to keys in the computerized key security system
(*i.e.* , system administrator) to ensure that player interface drop and
count keys are restricted to authorized persons.

\(ii\) In the event of an emergency or the key box is inoperable, access
to the emergency manual key(s) (a.k.a. override key), used to access the
box containing the player interface drop and count keys, requires the
physical involvement of at least three persons from separate
departments, including management. The date, time, and reason for
access, must be documented with the signatures of all participating
persons signing out/in the emergency manual key(s).

\(iii\) The custody of the keys issued pursuant to paragraph (u) (2)
(ii) of this section, requires the presence of two persons from separate
departments from the time of their issuance until the time of their
return.

\(iv\) Routine physical maintenance that requires accessing the
emergency manual key(s) (override key) and does not involve the
accessing of the player interface drop and count keys, only requires the
presence of two persons from separate departments. The date, time and
reason for access must be documented with the signatures of all
participating persons signing out/in the emergency manual key(s).

\(3\) For computerized key security systems controlling access to player
interface drop and count keys, accounting/audit personnel, independent
of the system administrator, will perform the following procedures:

\(i\) Daily, review the report generated by the computerized key
security system indicating the transactions performed by the
individual(s) that adds, deletes, and changes user\'s access within the
system ( *i.e.* , system administrator). Determine whether the
transactions completed by the system administrator provide an adequate
control over the access to the player interface drop and count keys.
Also, determine whether any player interface drop and count key(s)
removed or returned to the key cabinet by the system administrator was
properly authorized.

\(ii\) For at least one day each month, review the report generated by
the computerized key security system indicating all transactions
performed to determine whether any unusual player interface drop and
count key removals or key returns occurred.

\(iii\) At least quarterly, review a sample of users that are assigned
access to the player interface drop and count keys to determine that
their access to the assigned keys is adequate relative to their job
position.

\(iv\) All noted improper transactions or unusual occurrences are
investigated with the results documented.

\(4\) Quarterly, an inventory of all count room, drop box release,
storage rack and contents keys is performed, and reconciled to records
of keys made, issued, and destroyed. Investigations are performed for
all keys unaccounted for, with the investigation being documented.

\(v\) *Card games computerized key security systems.* (1) Computerized
key security systems which restrict access to the card game drop and
count keys through the use of passwords, keys or other means, other than
a key custodian, must provide the same degree of control as indicated in
the aforementioned key control standards, refer to paragraphs (n), (o),
(q), and (s) of this section. Note: This standard does not apply to the
system administrator. The system administrator is defined in paragraph
(k) (2)(ii) of this section.

\(2\) For computerized key security systems, the following additional
card game key control procedures apply:

\(i\) Management personnel independent of the card game department
assign and control user access to keys in the computerized key security
system ( *i.e.* , system administrator) to ensure that card game drop
and count keys are restricted to authorized persons.

\(ii\) In the event of an emergency or the key box is inoperable, access
to the emergency manual key(s) (a.k.a. override key), used to access the
box containing the card game drop and count keys, requires the physical
involvement of at least three persons from separate departments,
including management. The date, time, and reason for access, must be
documented with the signatures of all participating persons signing
out/in the emergency manual key(s).

\(iii\) The custody of the keys issued pursuant to paragraph (v) (2)(ii)
of this section, requires the presence of two persons from separate
departments from the time of their issuance until the time of their
return.

\(iv\) Routine physical maintenance that requires accessing the
emergency manual key(s) (override key) and does not involve the
accessing of the card games drop and count keys, only requires the
presence of two persons from separate departments. The date, time and
reason for access must be documented with the signatures of all
participating persons signing out/in the emergency manual key(s).

\(3\) For computerized key security systems controlling access to card
games drop and count keys, accounting/audit personnel, independent of
the system administrator, will perform the following procedures:

\(i\) Daily, review the report generated by the computerized key
security system indicating the transactions performed by the
individual(s) that adds, deletes, and changes user\'s access within the
system ( *i.e.* , system administrator). Determine whether the
transactions completed by the system administrator provide an adequate
control over the access to the card games drop and count keys. Also,
determine whether any card games drop and count key(s) removed or
returned to the key cabinet by the system administrator was properly
authorized.

\(ii\) For at least one day each month, review the report generated by
the computerized key security system indicating all transactions
performed to determine whether any unusual card games drop and count key
removals or key returns occurred.

\(iii\) At least quarterly, review a sample of users that are assigned
access to the card games drop and count keys to determine that their
access to the assigned keys is adequate relative to their job position.

\(iv\) All noted improper transactions or unusual occurrences are
investigated with the results documented.

\(4\) Quarterly, an inventory of all count room, card game drop box
release, storage rack and contents keys is performed, and reconciled to
records of keys made, issued, and destroyed. Investigations are
performed for all keys unaccounted for, with the investigations being
documented.

\(w\) *Emergency drop procedures.* Emergency drop procedures shall be
developed by the Tribal gaming regulatory authority, or the gaming
operation as approved by the Tribal gaming regulatory authority.

\(x\) *Equipment standards for player interface count.* (1) A weigh
scale calibration module shall be secured so as to prevent unauthorized
access (e.g., prenumbered seal, lock and key, etc.).

\(2\) A person independent of the cage, vault, player interface, and
count team functions shall be required to be present whenever the
calibration module is accessed. Such access shall be documented and
maintained.

\(3\) If a weigh scale interface is used, it shall be adequately
restricted so as to prevent unauthorized access (passwords, keys, etc.).

\(4\) If the weigh scale has a zero adjustment mechanism, it shall be
physically limited to minor adjustments (e.g., weight of a bucket) or
physically situated such that any unnecessary adjustments to it during
the weigh process would be observed by other count team members.

\(5\) Unannounced weigh scale and weigh scale interface (if applicable)
tests shall be performed by a person or persons independent of the cage,
vault, and bingo departments and count team at least quarterly with the
test results being documented and maintained. This test may be performed
by internal audit. The result of these tests shall be documented and
signed by the person or persons performing the test.

\(6\) Immediately prior to the player interface count, at least two
persons shall verify the accuracy of the weigh scale with varying
weights or with varying amounts of previously counted coin for each
denomination to ensure the scale is properly calibrated (varying
weights/coin from drop to drop is acceptable).

\(7\) If a mechanical coin counter is used (instead of a weigh scale),
the Tribal gaming regulatory authority, or the gaming operation as
approved by the Tribal gaming regulatory authority, shall establish and
the gaming operation shall comply with procedures that are equivalent to
those described in paragraphs (x) (4), (x) (5), and (x) (6) of this
section.

\(8\) If a coin meter count machine is used, the count team member shall
record the machine number denomination and number of coins in ink on a
source document, unless the meter machine automatically records such
information.

\(i\) A count team member shall test the coin meter count machine before
the actual count to ascertain if the metering device is functioning
properly with a predetermined number of coins for each denomination.

\(ii\) \[Reserved\]