Respectfully,

fl MEL

John A, Eck, C.F.E.

Assistant Manager of Gaming Compliance

JAE/jae

ce, Bill Lance
Clint Chadwick
Pat Neeley
Jeanna Gregory

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OFFICE OF THE GAMING COMMISSIONER
The Chickasaw Nation
902 Arlington, PMB 228 ¢ Ada, Oklahoma 74821
(580) 310-0570 ¢ Fax (580) 310-0571

July 19, 2013

Hon, Tracie Stevens

Chairwoman

National Indian Gaming Commission
1441 L Street NW, Suite 9100
Washington, DC 2005

Re: Approved Alternate Minimum Standard
Dear Chairwoman Stevens:

Tn accordance with 543.5 of the MICS, I am writing to inform you that an approved alternate
minimum standard for section 543.17 of the MICS has been approved. The revised TICS and request to use an
alternate minimum standard were approved electronically by former Commissioner Matthew Morgan. Please
find the approved version of TICS along with an explanation of how the alternate standard achieves a level of
security and integrity sufficient to accomplish the purpose of the standard it is to replace.

Should you have any questions, or if any further information is needed, please feel free to contact my
office at (580) 310-0570

Sincerg

YSoftt Lol
Gaming Commissioner



Bill Anoatubby

Chickasaw Nation Governor
Bill Lance

Department of Commerce Searetary of
Office: 2020 E, Lonnie Abbott Blvd. / Ada, OK 74820 Commerce

Phone; 580-421-9500

May 3, 2013
Sent Via MKS Integrity

Mr. Matthew Morgan
Gaming Commissioner
1500 North Country Club
Ada, OK 74820

Re: Request for approval to utilize an alternate minimum standard as stated in the NIGC MICS
at 25 CFR 543.5.

Dear Mr. Morgan

The CNDC respectfully requests approval to follow an alternate minimum standard instead of
the two 543.17 standards listed below:

543.17)(14)(iv) The cage/vault agent receiving the transferred drop proceeds must sign the
count sheet attesting to the verification of the total received, and thereby assume accountability
of the drop proceeds, ending the count.

543.17(g)(16){iv) The cage/vault agent receiving the transferred drop proceeds must sign the
count sheet attesting to the verification of the total received, and thereby assuming
accountability of the drop proceeds, and ending the count.

Currently the CNDC utilizes a true blind count, whereby the vault has absolutely no knowledge
of the soft count totals, which complies with the MICS. CNDC does not currently pass the count
sheet through to the vault for a signature at any time. CNDC currently passes the soft count
funds/drop proceeds through to the vault after the soft count; then the vault performs an
independent count and signs the Daily Activity Report (DAR) to attest to the accuracy of the
drop proceeds received and counted. CNDC believes the two standards above are less efficient
than our current processes and offer less control.

CNDC’s current processes achieve the same level of security and integrity as the standards set
forth in the two 543.17 standards referenced above. Below is our explanation of how that level
of security and integrity is accomplished as required in 543.5:
1. Our current processes provide the same blind/independent count but do not offer the soft
count totals to the vault at any time. Immediately following the soft count, the funds are

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passed to the vault for verification and either a soft count employee or a security officer
delivers the count sheets to accounting. The vault personnel will perform their count of
the drop funds and call accounting with the verification totals, At this point, the two
blind counts of the drop funds are confirmed by an accounting employee who either
approves the funds to be added to the vault inventory or tells the vault they need to
recount,

2. Our current processes do not require a soft count employee to remain in the soft count
room until the vault has counted/verified the drop proceeds for their signature on the
count sheet. The 543.17 standards state that a vault agent will sign the count sheet
“attesting to the verification of the total received” which requires that the vault count the
funds before signing the soft count sheet. This process will subsequently require that a
soft count employee remain in the count room with the count sheet to obtain the vault
signature and then deliver the count sheets to accounting. This is less efficient than our
current process.

CNDC’s proposed TICS language follows:

343.1 7(M(14)(iv) The cage/vault agent receiving the transferred drop proceeds must sign the

count sheet attesting to the verification of the total received. and thereby assume accountability
of the drop proceeds, ending the count,
TICS:

Alternatively, CNDC will continue to follow the controls of a blind count in soft count and
vault. The count sheet will not be Passed to the vault as stated in (i) and (ii) above. The count
team will pass the counted drop funds to the vault thus ending the count. The vault shall verify
the drop proceeds received and certify by signature on the DAR as to the accuracy of those
proceeds,

543.17(2)(16)(iv) The cage/vault agent receiving the transferred drop proceeds must sign the

count sheet attesting to the verification of the total received, and thereby assuming accountability

of the drop proceeds, and ending the count.

TICS: Alternatively, CNDC will continue to follow the controls of a blind count in soft count and
vault. The count sheet will not be passed to the vault as stated in (i) and (ii) above. The count
team will pass the counted drop funds to the vault thus ending the count, The vault shall verify
the drop proceeds received and certify by signature on the DAR as to the accuracy of those

proceeds,

Please consider our request and provide your response,

If | may be of any assistance please let me know.

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