Exhibit 4.16

233
South Wacker Drive, Suite 2800
Chicago, Illinois 60606
Tel 312-234-2732
Fax 312-234-3603

Bank of America N. A.

TO:
Mandalay Resort Group
2880 LasVegas Blvd-South
Las Vegas, NV 89109
ATTN: Amy Preiss
TEL: 702 632 6820
FAX: 702 632 6822

FROM:
Bank of America, N.A.
233 South Wacker DriveSuite 2800
Chicago, Illinois 60606
Robert OHara / Paul Enright
Date: 13FEB03

Our
Reference No. 3033348
Internal Tracking Nos. 7374064 7374064

The
purpose of this letter agreement is to confirm the terms and conditions of the Transaction entered into between Mandalay Resort Group and Bank of America, N.A. (each a "party" and
together "the parties") on the Trade Date specified below (the "Transaction"). This letter agreement constitutes a "Confirmation" as referred to in the ISDA Master Agreement specified in
paragraph 1 below (the "Agreement").

The
definitions and provisions contained in the 2000 ISDA Definitions, as published by the International Swaps and Derivatives Association, Inc., (the "Definitions") are
incorporated into this
Confirmation. In the event of any inconsistency between the Definitions and this Confirmation, this Confirmation will govern.

1.    This
Confirmation supplements, forms part of, and is subject to, the ISDA Master Agreement dated as of 24OCT86, as amended and supplemented from time to time (the
"Agreement"), between the parties. All provisions contained in the Agreement govern this Confirmation except as expressly modified below. In this Confirmation "Party A" means Bank of America, N.A. and
"Party B" means Mandalay Resort Group.

2.    The
terms of the particular Transaction to which this Confirmation relates are as follows:



---



---



3.    Recording of Conversations:Each party to this Transaction acknowledges and agrees to the tape recording of conversations
between the parties to this Transaction whether by one or other or both of the parties or their agents, and that any such tape recordings may be submitted in evidence in any Proceedings relating to
the Agreement and/or this Transaction.

4.    Account Details:



5.    Offices:



Credit Support Document:As per Agreement (and Credit Support Annex if applicable).

Please
confirm that the foregoing correctly sets forth the terms and conditions of our agreement by returning via telecopier an executed copy of this Confirmation to the attention of
Global Derivative Operations at (fax no.(312) 234-3603).

---

Yours
Sincerely,

|Bank of America, N.A.                                |  |                                                                     
|---------------------------------------------------- |  | --------------------------------------------------------------------
|By:
Name:
Title:                                     |  | /S/ DAVE WALKERDave Walker Senior Vice President                    
|Authorized Signatory                                 |  |                                                                     
|Accepted and confirmed as of the date first written: |  |                                                                     
|Mandalay Resort Group                                |  |                                                                     
|By:
Name:
Title:                                     |  | /S/ LES MARTINLes Martin Vice President and Chief Accounting Officer

Our
Reference # 3033348 7374064

---

QuickLinks