§543.19 What are the minimum internal control standards for accounting? 

(a) Each gaming operation shall prepare accurate, complete, legible, and permanent 

records of all transactions pertaining to revenue and gaming activities. 

(b) Each gaming operation shall prepare general accounting records according to 

Generally Accepted Accounting Principles using a double-entry system of accounting, 

and shall maintain detailed, supporting, subsidiary records, including, but not limited to: 

(1) Detailed records identifying revenues, expenses, assets, liabilities, and equity for each 

gaming operation; 

(2) Detailed records of all markers, IOU's, returned checks, held checks, or other similar 

credit instruments; 

(3) Card game statistical game records reflecting drop by each table by shift, by day, 

cumulative month-to-date, and year-to-date. 

(4) Bingo analysis reports which, by each player interface (game) compare actual hold 

percentages to expected hold percentages; 

Written Comment (March): Class II bingo games are system based. The player 

interface in a Class II system is a dumb terminal and statistical info may not be 

available per player interface. A comparable example in paper bingo would be 

that the player in seat 27 in a bingo hall wins more or less than the player in seat 

32. This provides no relevant data in assessing the performance of the bingo 

game. The analysis report should address the compilation at the system level in 

regard to numerous game play. 

This standard should apply equally to both paper and electronic format. 

Therefore, we recommend that the proposed language be revised to read as 

follows: “Bingo analysis reports which compare actual hold percentages to 

expected hold percentages.” 

Remove “(game)”: a player interface is not a game. 

7-8-10 Version 

Page 1 of 14 
Response: This represents an error in the transition from 542 to 543. It has no 

relevance to 543.7 Bingo section. Standard will be deleted. 

Proposed deletion as a result of March written comment: 

(4) Bingo analysis reports which, by each player interface (game) compare actual 

hold percentages to expected hold percentages; 

(4) (5) Other records required by this part and by the Tribal internal control standards; 

(5) (6) Journal entries prepared by the gaming operation and by its independent 

accountants; and 

(6) (7) Any other records specifically required to be maintained. 

Written Comment (March): (b) (5) and (b) (7) appear to be redundant. Please 

clarify the need for having both standards. 

Response: The Committee reviewed the proposed regulation and made no 

comment. (b)(5) refers only to records required by 543 and by the TICS. Other 

records could be required to be maintained by any external entity.

This comment has no bearing on the transition from 542 to 543. 

(c) Each gaming operation shall establish administrative and accounting procedures for 

the purpose of determining effective control over a gaming operation's fiscal affairs. The 

procedures shall be designed to reasonably ensure that: 

(1) Assets are safeguarded; 

(2) Financial records are accurate and reliable; 

(3) Transactions are performed only in accordance with management's general and 

specific authorization; 

Written Comment (March): Add “pursuant to tribal internal control standards” 

to the end of the sentence. 

Response: The Committee reviewed the proposed regulation and made no 

comment. Disagree. “Management’s general and specific authorization” is an 

7-8-10 Version 

Page 2 of 14 
accounting term of art.” This comment has no bearing on the transition from 542 

to 543. 

(4) Transactions are recorded adequately to permit proper reporting of gaming revenue 

and of fees and taxes, and to maintain accountability of assets; 

 Written Comment (March): Replace “taxes” with “assessments”. 

Response: The Committee reviewed the proposed regulation and made no 

comment. In this context the standard is referring to excise taxes on certain types 

of gaming revenue. This comment has no bearing on the transition from 542 to 

543. 

Note (May): Although the word “taxes” is limited to taxes on specific types of 

gaming revenue, the word could cause confusion and therefore it is recommended 

to be struck. 

Proposed revision incorporating May note: 

(4) Transactions are recorded adequately to permit proper reporting of gaming revenue

and of fees and taxes, and to maintain accountability of assets; 

(5) Recorded accountability for assets is compared with actual assets at reasonable 

intervals, and appropriate action is taken with respect to any discrepancies; and 

(6) Functions, duties, and responsibilities are appropriately segregated in accordance with 

sound business practices. 

Written Comment (March): Add “generally accepted accounting principles” 

before the word “sound”. 

Response: The Committee reviewed the proposed regulation and made no 

comment. The addition of “generally accepted accounting principles” would be 

redundant as it is already stated in (b). This comment has no bearing on the 

transition from 542 to 543. 

(d) Gross gaming revenue computations. (1) For player interfaces, gross revenue equals 

drop, less fills, prize payouts and personal property awarded to patrons as gambling 

winnings. 

7-8-10 Version 

Page 3 of 14 
(2) For each counter game, gross revenue equals: 

(i) The cash accepted by the gaming operation on events or games that occur during the 

month or will occur in subsequent months, less cash paid out during the month to patrons 

on winning wagers (“cash basis''); or 

(ii) The cash accepted by the gaming operation on events or games that occur during the 

month, plus cash, not previously included in gross revenue, that was accepted by the 

gaming operation in previous months on events or games occurring in the month, less 

cash paid out during the month to patrons as winning wagers (“modified accrual basis''). 

(3) For each card game, gross revenue equals all cash received by the operation as 

compensation for conducting the game. 

(i) A gaming operation shall not include either shill win or loss in gross revenue 

computations. 

(ii) [Reserved] 

(4) In computing gross revenue for bingo and pull tabs, the actual cost to the gaming 

operation of any personal property (other than costs of travel, lodging, services, food, and 

beverages) awarded as a payout to patrons may be deducted if the gaming operation 

maintains detailed documents supporting the deduction. 

Written Comment (March): If the intent of the parenthetical is to exclude 

comps from the computation of GGR, then the language needs to be revised 

accordingly. As the proposed language currently reads the gaming operation 

would be precluded from giving away trips, etc. as prizes and then deducting it 

from the GGR computation. 

Response: The Committee reviewed the proposed standard and had no comment. 

The intent of the language is to exclude the deduction of the cost of travel, 

lodging, services, food and beverages from the computation of GGR due to the 

difficulty in quantifying the value of these items and the susceptibility to 

manipulation. The commenter is correct that the items listed are not deductible in 

7-8-10 Version 

Page 4 of 14 
calculating gross gaming revenue. This comment has no bearing on the transition 

from 542 to 543. 

(e) Each gaming operation shall establish internal control systems sufficient to ensure that 

currency (other than tips or gratuities) received from a patron in the gaming area is 

promptly placed in a locked box in the table, or, in the case of a cashier, in the 

appropriate place in the cashier's cage, or on those games which do not have a locked 

drop box, or on card game tables, in an appropriate place on the table, in the cash register 

or in another approved repository. 

(f) If the gaming operation provides periodic payments to satisfy a prize payout resulting 

from a wager, the initial installment payment, when paid, and the actual cost of a 

payment plan, which is funded by the gaming operation, may be deducted from winnings. 

The gaming operation is required to obtain the approval of all payment plans from the 

Tribal gaming regulatory authority. For any funding method which merely guarantees the 

gaming operation's performance, and under which the gaming operation makes payments 

out of cash flow (e.g. irrevocable letters of credits, surety bonds, or other similar 

methods), the gaming operation may only deduct such payments when paid to the patron. 

(g) Vouchers issued at a player interface shall be deducted from gross revenue as prize 

payouts in the month the vouchers are issued by the player interface. Vouchers deducted 

from gross revenue that are not redeemed within a period, not to exceed 180 days of 

issuance, shall be included in gross revenue. An unredeemed voucher previously included 

in gross revenue may be deducted from gross revenue in the month redeemed. 

(h) A gaming operation may not deduct from gross revenues the unpaid balance of a 

credit instrument extended for purposes other than gaming. 

7-8-10 Version 

Page 5 of 14 
Written Comment (March): It is our opinion that this proposed standard is 

unnecessary as GGR is defined in other NIGC regulations. 

Response: The Committee reviewed the proposed standard and had no comment. 

Disagree with comment. Standard is intended to clarify that if the credit 

instrument is used for something other than gaming purposes, it is not deductible. 

This comment has no bearing on the transition from 542 to 543. 

(i) A gaming operation may deduct from gross revenue the unpaid balance of a credit 

instrument if the gaming operation documents, or otherwise keeps detailed records of, 

compliance with the following requirements. Such records confirming compliance shall 

be made available to the Tribal gaming regulatory authority or the Commission upon 

request: 

(1) The gaming operation can document that the credit extended was for gaming

purposes; 

(2) The gaming operation has established procedures and relevant criteria to evaluate a 

patron’s credit reputation or financial resources and to then determine that there is a 

reasonable basis for extending credit in the amount or sum placed at the patron’s 

disposal; 

(3) In the case of personal checks, the gaming operation has established procedures to 

examine documentation, which would normally be acceptable as a type of identification 

when cashing checks, and has recorded the patron’s bank check guarantee card number or 

credit card number, or has satisfied paragraph (i) (2) of this section, as management may 

deem appropriate for the check-cashing authorization granted; 

(4) In the case of third-party checks for which cash, chips, or tokens have been issued to 

the patron, or which were accepted in payment of another credit instrument, the gaming

operation has established procedures to examine documentation, normally accepted as a 

7-8-10 Version 

Page 6 of 14 
means of identification when cashing checks, and has, for the check's maker or drawer, 

satisfied paragraph (i) (2) of this section, as management may deem appropriate for the 

check-cashing authorization granted; 

(5) In the case of guaranteed drafts, procedures should be established to ensure 

compliance with the issuance and acceptance procedures prescribed by the issuer; 

(6) The gaming operation has established procedures to ensure that the credit extended is 

appropriately documented, not least of which would be the patron’s identification and 

signature attesting to the authenticity of the individual credit transactions. The 

authorizing signature shall be obtained at the time credit is extended. 

(7) The gaming operation has established procedures to effectively document its attempt 

to collect the full amount of the debt. Such documentation includes, but is not limited to, 

letters sent to the patron, logs of personal or telephone conversations, proof of 

presentation of the credit instrument to the patron’s bank for collection, settlement 

agreements, or other documents which demonstrate that the gaming operation has made a 

good faith attempt to collect the full amount of the debt. Such records documenting 

collection efforts shall be made available to the Tribal gaming regulatory authority or the 

Commission upon request. 

(j) Allowable and non-allowable deductions from gross revenue. (1) Any prizes, 

premiums, drawings, benefits or tickets that are redeemable for cash or merchandise or 

other promotional allowance, except cash or tokens paid at face value or the cost of 

personal property awarded directly to a patron as the result of a specific wager, must not 

be deducted. 

(2) Cash paid to fund periodic payments may be deducted. 

7-8-10 Version 

Page 7 of 14 
(3) For bingo and pull tabs, the actual cost of any personal property distributed to a 

patron as the result of a specific legitimate wager may be deducted, but not travel 

expenses, food, refreshments, lodging, or services. 

Comment (March): The issue here is the difference between a COMP and an 

advertised prize as a result of a wager. If the NIGC intends for prizes paid to be 

deductible then that is what should be articulated in this proposed standard. 

A COMP is not a result of a wager. So, if the NIGC is intending to prohibit the 

cost of COMPS from GGR then that should be clearly articulated in this proposed 

standard. 

Response: The Committee reviewed the proposed standard and had no comment. 

The intent of the language is to exclude the deduction of the cost of travel, 

lodging, services, food and beverages from the computation of GGR due to the 

difficulty in quantifying the value of these items and the susceptibility to 

manipulation. The commenter is correct that the items listed are not deductible in 

calculating gross gaming revenue. This comment has no bearing on the transition 

from 542 to 543. 

(4) A gaming operation that provides a patron with additional play at bingo as the result 

of an initial wager may deduct all cash or tokens paid directly to that patron as a result of 

such additional play. 

(5) A gaming operation may deduct its pro-rata share of a payout from a game played in a 

wide area linked system except for a payout made in conjunction with a card game. The 

amount of the deduction must be determined based upon the written agreement among 

the gaming establishments participating in the wide area linked system and the operator 

of the system. All cash prizes and the value of noncash prizes awarded during a contest or 

tournament conducted in conjunction with a wide area linked system are also deductible 

on a pro-rata basis to the extent of the compensation received for the right to participate 

in that contest or tournament. 

 Comment (March): Please clarify why there is a “card game” reference in this

 proposed standard? Is there a linked system or WAP for card games? 

7-8-10 Version 

Page 8 of 14 
Response: The Committee reviewed the proposed revision and made no 

comment. The possibility exists for wide area linked poker games and for that 

reason the standard recognizes that the house has no interest in the payout that 

might arise from that operation and therefore, it would not be deductible. The 

comment has no bearing on the transition from 542 to 543. 

(6) Deductibility of free play and promotional items: 

(i) Card Games

(A) Buy-in coupons (e.g., $25 in chips for $20 

buy-in) 

No effect on revenue 

Written Comment (March): Does “no 

effect on revenue” mean deductible or 

non-deductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(B) Tournaments played with negotiable chips 

and rake is taken 

Rake is included in revenue. No effect 

on revenue

Written Comment (March): 

Deductible or Not Deductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(C) Tournaments played with non-negotiable 

chips, contests and drawings 

No effect on revenue. Written 

Comment (March): Does “no effect on 

revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(D) Prizes (e.g., $100 prize for high hand of the 

week) 

No effect on revenue. Written 

Comment (March): Does “no effect on 

revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

7-8-10 Version 

Page 9 of 14 
comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(E) Promotional progressive pot and/or pool 

payouts 

No effect on revenue. Written 

Comment (March): Does “no effect on 

revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(F) Shill wins and losses No effect on revenue. Written 

Comment (March): Does “no effect on 

revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(ii) Bingo 

(A) Match play/discount wagering Include cash received in sales and all 

payouts deductible 

(B) Free play wagering (negotiable and nonnegotiable) No effect on sales and all payouts 

deductible 

(C) Non-cash prizes Include cash received in sales and 

purchase cost of prizes deductible 

(D) Promotional activity reimbursement by 

external party 

Include cash received sales and all 

payouts deductible 

(E) Tournaments/contests/drawings No effect on sales unless part of 

wide area linked system.

(F) Tournaments which include elements of a Include total amount wagered in 

7-8-10 Version 

Page 10 of 14 
normal wager sales, all payouts deductible, 

tournament prizes not deductible

(E) (G) Appeasement payouts (payments made 

on non-winning cards in response to patron 

complaints)

Not deductible 

(iii) Pull Tabs 

(A) Match play/discount wagering Include cash received in sales and all 

payouts deductible 

(B) Free play wagering (negotiable and nonnegotiable) No effect on sales and all payouts 

deductible 

(C) Non-cash prizes Include cash received in sales and 

purchase cost of prizes deductible 

(D) Promotional activity reimbursement by 

external party 

Include cash received in sales and all 

payouts deductible 

(E) Tournaments/contests/drawings No effect on sales unless part of wide 

area linked system.

(F) Tournaments which include elements of a 

normal wager

Include total amount wagered in 

sales, all payouts deductible, 

tournament prizes not deductible

(E) (G) Appeasement payouts (payments made 

on non-winning pull tabs in response to patron 

complaints)

Not deductible 

7-8-10 Version 

Page 11 of 14 
Comment (July): Strike (j) (5) (ii) (E) and (F), not applicable to bingo. 

Response: Agree. 

Revised proposal (j) (5) (ii) (E) and (F) as a result of July comments: (j) (5) (ii) (E) and 

(F) struck from matrix (above). 

Comment (July): Strike (j) (5) (iii) (E) and (F), not applicable to pull tabs. 

Response: Agree. 

Revised proposal (j) (5) (iii) (E) and (F) as a result of July comments: (j) (5) (iii) (E) and 

(F) struck from matrix (above). 

(7) Credit instruments written off as uncollectible are deductible unless any of the 

following applies: 

(i) The instrument was not signed by the patron; 

(ii) The gaming operation did not have an address for the patron at the time of accepting 

the instrument; 

(iii) The gaming operation does not maintain evidence that it has made a reasonable effort 

to collect the debt; 

(iv) The gaming operation does not maintain evidence that it checked the credit history of 

the patron before extending the credit; 

(v) The signature of the patron on the instrument was forged and the gaming operation 

has not made a written report of the forgery to the appropriate law enforcement agency; 

or 

(vi) The gaming operation is unable to produce the credit instrument within a reasonable 

time after a request by the Commission. (Note: However, this shall not pertain to 

circumstances beyond the control of the gaming operation e.g., custody of court, stolen, 

etc.) 

(k) Maintenance and preservation of books, records, and documents. (1) All original 

books, records, and documents pertaining to the conduct of wagering activities shall be

7-8-10 Version 

Page 12 of 14 
retained by a gaming operation in accordance with the following schedule. A record that 

summarizes gaming transactions is sufficient, provided that all documents containing an 

original signature(s) attesting to the accuracy of a gaming related transaction are 

independently preserved. Original books, records, or documents shall not include copies 

of originals, except for copies that contain original comments or notations on parts of 

multi-part forms. The following original books, records, and documents shall be retained 

by a gaming operation for a minimum of five (5) years: 

(i) Casino cage documents; 

(ii) Documentation supporting the calculation of bingo win; 

(iii) Documentation supporting the calculation of revenue received from card games, and 

all other gaming activities offered by the gaming operation; 

(iv) Bingo statistical reports; 

(v) Pull tab statistical reports; 

(vi) Internal audit documentation and reports; 

Written Comment (March): Recommend deleting “documentation” from this 

standard as the entity that conducts the internal audit will have to comply with the 

internal audit portion of the MICS. This will vary from one jurisdiction to 

another. 

Response: The Committee reviewed the proposed revision and had no comment. 

Disagree with comment. Removing the reference to documentation would imply 

that only the report needs to be retained for five years. This comment has no 

bearing on the transition from 542 to 543.

(vii) Documentation supporting the write-off of gaming credit instruments and named 

credit instruments; 

7-8-10 Version 

Page 13 of 14 
(viii) All other books, records, and documents pertaining to the conduct of wagering 

activities that contain original signature(s) attesting to the accuracy of the gaming related 

transaction. 

(2) Unless otherwise specified in this part, all other books, records, and documents shall 

be retained until such time as the accounting records have been audited by the gaming

operation's independent certified public accountants. 

(3) The above definition shall apply without regard to the medium by which the book, 

record or document is generated or maintained (paper, computer-generated, magnetic 

media, etc.). 

Written Comment (March): Replace “definition” with “standard”. 

Response: The Committee reviewed the proposed revision and had no comment. 

Disagree with comment. “Definition” refers to original books, records and 

documents” not to the standards for retention. This comment has no bearing on 

the transition from 542 to 543. 

Note (May): As a result of the discussion during the conference call, it was 

decided to substitute “standards” for “definition” to improve clarity. 

(3) The above definition standards shall apply without regard to the medium by which 

the book, record or document is generated or maintained (paper, computer-generated, 

magnetic media, etc.). 

 

7-8-10 Version 

Page 14 of 14