§542.12 What are the minimum internal control standards for table games? 

(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) Standards for drop and count. The procedures for the collection of the table game 

drop and the count thereof shall comply with §542.21, §542.31, or §542.41 (as 

applicable). 

(c) Fill and credit standards. (1) Fill slips and credit slips shall be in at least triplicate 

form, and in a continuous, prenumbered series. Such slips shall be concurrently 

numbered in a form utilizing the alphabet and only in one series at a time. The alphabet 

need not be used if the numerical series is not repeated during the business year. 

(2) Manual unissued Unissued and issued fill/credit slips shall be safeguarded and 

adequate procedures shall be employed in their distribution, use, and control. Personnel 

from the cashier cage or pit table games departments shall have no access to the 

secured locked box (control) copies of the fill/credit slips. For computerized systems, 

one part shall be stored in the computer system in such manner that prevents pit, 

cage and other unauthorized persons from accessing and making changes to the 

stored information.

 Comment (January): Please provide clarification of the “lock box” reference in 

this section. 

Response: The “locked box” copies refer to the control copies that are 

maintained in what is commonly referred to as a “whiz machine”.

Comment (January): If the “locked box” was referred to as a whiz machine in 

the Cage (542.14) section, parenthetically or otherwise, the same reference 

should be included in this section. 

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Response: There is no reference to a whiz machine in the Cage 542.14 

Section. However, to clarify, the reference will be changed to “locked (whiz) 

machine”. Modified accordingly. 

Proposed revision as a result of January comment: 

(2) Manual unissued Unissued and issued fill/credit slips shall be safeguarded and 

adequate procedures shall be employed in their distribution, use, and control. Personnel 

from the cashier cage or pit departments shall have no access to the secured locked 

(whiz) machine (control) copies of the fill/credit slips. For computerized systems, one 

part shall be stored in the computer system in such manner that prevents pit, cage 

and other unauthorized persons from accessing and making changes to the stored 

information.

Comment (January): Please provide clarification on the risk that is being 

mitigated in the proposed language. This language may need to be moved to a 

subsection as it does not appear to fit within the category of a manual function. 

Response: The intent of the proposed language is to clarify that the control 

copy of the slip need not be a hard copy; it may be a computerized copy. 

Comment (March): As previously recommended, reference to “pit department” 

should be changed to “table games department.” 

Response: Agreed. Modified accordingly. 

Proposed revision as a result of March comment: 

(2) Manual unissued Unissued and issued fill/credit slips shall be safeguarded and 

adequate procedures shall be employed in their distribution, use, and control. Personnel 

from the cashier cage or pit table games departments shall have no access to the 

secured locked (whiz) machine (control) copies of the fill/credit slips. For 

computerized systems, one part shall be stored in the computer system in such 

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manner that prevents table games, cage and other unauthorized persons from 

accessing and making changes to the stored information.

(3) When a fill/credit slip is voided, the cashier shall clearly mark “void” across the face 

of the original and first copy, the cashier and one other person independent of

performing the transactions void shall sign both the original and first copy, and shall 

submit them to the accounting department for retention and accountability. For 

computer-generated fill/credit slips, the computer system shall be updated to reflect 

the voided fill/credit transaction. 

Comment (January): Please insert the words “by authorized personnel” after 

the word “updated” to allow for a control of voids in a computerized system. It 

is our understanding that the computerized system, tribal internal controls, and 

gaming operation SOPs will dictate which authorized personnel will be able to 

perform this function. 

Response: Agreed. Modified accordingly. Note: Following a lengthy 

discussion, it appeared that the concern revolved around which personnel were 

or should be authorized to verify the void rather than which personnel were or 

should be authorized to update the computer system. 

Proposed revision as a result of January comment: 

(3) When a fill/credit slip is voided, the cashier shall clearly mark “void” across the face 

of the original and first copy, the cashier and one other person independent of

performing the transactions void shall sign both the original and first copy, and shall 

submit them to the accounting department for retention and accountability. For 

computer-generated fill/credit slips, the computer system shall be updated by 

authorized personnel to reflect the voided fill/credit transaction. 

(4) Fill/credit transactions shall be authorized by pit table games supervisory personnel 

before the issuance of fill/credit slips and transfer of chips, tokens, or cash equivalents. 

The fill request shall be communicated to the cage where the fill slip is prepared.

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 Comment (January): Please provide clarification of the words “the issuance 

of”. 

Response: Generation of the fill or credit “slip” 

(5) Unless the chips, tokens, and/or monetary equivalents (e.g., credit instruments, 

coin) being transferred from the tables to the cage are accompanied by a credit slip, 

an order for credit shall be prepared to accompany the inventory being transferred 

from the pit to the cashier area or other secure area of accountability. 

Comment (January): Is this section referring to a manual credit, fill request, 

etc? Please clarify. If this is a manual process then that needs to be articulated 

so as to avoid any confusion. 

Response: This could refer to either an electronic or a manual system. 

However, with the electronic there is not need to produce a physical document. 

(i) When an order for credit is prepared to accompany the chips, tokens, and/or 

monetary equivalents transferred, the duplicate copy of the order for credit shall be 

retained in the pit to compare to the credit slip for proper entries and to document 

the total amount of chips, tokens, and/or equivalents removed from the table.

(ii)[Reserved].

(5) (6) At least three parts of each fill/credit slip shall be utilized as follows: 

(i) One part shall be transported to the pit with the fill and, after the appropriate 

signatures are obtained, deposited in the table game drop box; For a fill, one part 

shall be transported to the pit with the chips, tokens, and/or monetary equivalents 

and, after the appropriate signatures are obtained, deposited in table game drop 

box. For a credit, one part shall be transported to the pit by the runner who 

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brought the chips, tokens, and/or monetary equivalents from the pit to the cage, and 

after the appropriate signatures are obtained, deposited in the table game drop box.

Comment (January): It is our opinion that this section needs to be separated out 

so as to distinguish “fills” from “credits” for readability. 

Response: Agreed. Modified accordingly. 

Proposed revision as a result of January comment: 

(5) (6) At least three parts of each fill slip shall be utilized as follows: 

(i) One part shall be transported to the pit with the fill and, after the appropriate 

signatures are obtained, deposited in the table game drop box; For fill slips-

(A) One part shall be transported from the cage to the pit with the chips, tokens, 

and/or monetary equivalents and, after the appropriate signatures are obtained, 

deposited in table game drop box.

(B) (ii) One part shall be retained in the cage for reconciliation of the cashier bank; and 

(C) (iii) For computer systems, one part shall be stored in the computer system

retained in a secure manner to insure that only authorized persons may gain access 

to it. For manual systems, one part shall be retained in a secure manner intact by the 

locked machine in a continuous unbroken form. 

(ii) For credit slips- 

(A) One part shall be transported to the pit by the runner who brought the chips, 

tokens, and/or monetary equivalents from the pit to the cage, and after the 

appropriate signatures are obtained, deposited in the table game drop box.

(B) One part shall be retained in the cage for reconciliation of the cashier bank; and

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(C) For computer systems, one part shall be stored in the computer system. For 

manual systems, one part shall be retained intact by the locked machine in a 

continuous unbroken form. 

Comment (January): Please provide clarification on the words “locked 

machine”. 

Response: “Locked machine” refers to the “whiz machine” referenced in (c) 

(2). References in (6) (i) (C) and (6) (ii) (C) modified for consistency with 

reference in (c) (2) 

Proposed revision as a result of January comment: 

(5) (6) At least three parts of each fill slip shall be utilized as follows: 

(i) One part shall be transported to the pit with the fill and, after the appropriate 

signatures are obtained, deposited in the table game drop box; For fill slips-

(A) One part shall be transported from the cage to the pit with the chips, tokens, 

and/or monetary equivalents and, after the appropriate signatures are obtained, 

deposited in table game drop box.

(B) (ii) One part shall be retained in the cage for reconciliation of the cashier bank; and 

(C) (iii) For computer systems, one part shall be stored in the computer system

retained in a secure manner to insure that only authorized persons may gain access 

to it. For manual systems, one part shall be retained in a secure manner intact by the 

locked (whiz) machine in a continuous unbroken form. 

(ii) For credit slips- 

(A) One part shall be transported to the pit by the runner who brought the chips, 

tokens, and/or monetary equivalents from the pit to the cage, and after the 

appropriate signatures are obtained, deposited in the table game drop box.

(B) One part shall be retained in the cage for reconciliation of the cashier bank; and

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(C) For computer systems, one part shall be stored in the computer system. For 

manual systems, one part shall be retained intact by the locked (whiz) machine in a 

continuous unbroken form. 

(6) (7) For Tier C gaming operations, the part of the fill/credit slip that is placed in the 

table game drop box shall be of a different color for fills than for credits, unless the type 

of transaction is clearly distinguishable in another manner (the checking of a box on the 

form shall not be a clearly distinguishable indicator). 

Comment (January): It is our recommendation that the reference to “Tier C” be 

removed and this control be revised to reflect that that fill/credit slips shall be 

distinguishable from one another. The manner in which the gaming operation 

and the TGRA choose to distinguish these forms is a local regulatory matter. 

Response: Disagree. Limiting the requirement to Tier C gaming operations 

does not preclude the TGRA from imposing the same requirement on Tier A or 

B gaming operations. 

(7) (8) The table number, shift, and amount of fill/credit by denomination and in total 

shall be noted on all copies of the fill/credit slip. The For manual slips, the correct date 

and time shall be indicated on at least two copies. For a computerized system, all 

copies must include the date and time. 

Note: Numbering has been corrected. 

(i) If the credit slip (manual or computerized) is for the transfer of a marker to the 

cage at the time other than for a mass marker transfer, the slip and order for credit 

(if utilized) must also include the marker number(s), customer’s name, amount of 

each marker(s), the total amount transferred, signature of table games supervisor 

releasing the instrument from the pit, and the signature of the cashier verifying 

receipt of the instrument at the cage; and

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(ii) A credit slip is not required when completing a mass marker transfer. Credit 

slip(s) are only required for credit instruments transferred from the pit to the cage 

when a mass marker transfer form is not used.

(8) (9) All fills/credits shall be carried to/from the cashier's cage by a person who is 

independent of the cage or pit and table games departments.

(9) (10) The fill/credit slip shall be signed by at least the following persons (as an 

indication that each has counted the amount of the fill/credit and the amount agrees with 

the fill/credit slip or, in the case of markers, reviewed the items transferred): 

(i) Cashier who prepared the fill slip and issued the chips, tokens, or cash equivalent, or 

prepared the credit slip and received the chips, tokens, and/or monetary equivalents 

transferred from the pit; 

(ii) Runner who carried the chips, tokens, or cash equivalents from the cage to the pit, or 

carried the chips, tokens, and/or monetary equivalents transferred from the pit to 

the cage and returned to the pit with the credit slip; 

(iii) Dealer or boxperson who received the chips, tokens, or cash equivalents at the 

gaming table, or had custody of the chips, tokens, and/or monetary equivalents prior 

to transfer to the cage. For marker credits, the dealer inserting the credit slip into 

the table game drop box; and 

Comment (January): Use of the words “had custody of” is peculiar. 

Recommend using some other expression. 

Response: Agreed. Modified accordingly. 

Proposed revision as a result of January comment: 

(iii) Dealer or boxperson who received the chips, tokens, or cash equivalents at the 

gaming table, or relinquished the chips, tokens, and/or monetary equivalents for 

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transfer to the cage. For marker credits, the dealer inserting the credit slip into the 

table game drop box; and 

(iv) Pit Table games supervisory personnel who supervised the fill/credit transaction. 

(10) (11) Fills/credits shall be broken down and verified by the dealer or boxperson in 

public view before the dealer or boxperson places the fill in the table tray or prior to 

placing them in racks for transfer to the cage, as applicable. 

(11) (12) A copy of the fill/credit slip shall then be deposited into the drop box on the 

table by the dealer, where it shall appear in the soft count room with the cash receipts for 

the shift. 

(12) Table credit transactions shall be authorized by a pit supervisor before the 

issuance of credit slips and transfer of chips, tokens, or other cash equivalent. The 

credit request shall be communicated to the cage where the credit slip is prepared.

(13) At least three parts of each credit slip shall be utilized as follows:

(i) Two parts of the credit slip shall be transported by the runner to the pit. After 

signatures of the runner, dealer, and pit supervisor are obtained, one copy shall be 

deposited in the table game drop box and the original shall accompany transport of 

the chips, tokens, markers, or cash equivalents from the pit to the cage for 

verification and signature of the cashier.

(ii) For computer systems, one part shall be retained in a secure manner to insure 

that only authorized persons may gain access to it. For manual systems, one part 

shall be retained in a secure manner in a continuous unbroken form.

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(14) The table number, shift, and the amount of credit by denomination and in total 

shall be noted on all copies of the credit slip. The correct date and time shall be 

indicated on at least two copies.

(15) Chips, tokens, and/or cash equivalents shall be removed from the table tray by 

the dealer or boxperson and shall be broken down and verified by the dealer or 

boxperson in public view prior to placing them in racks for transfer to the cage.

(16) All chips, tokens, and cash equivalents removed from the tables and markers 

removed from the pit shall be carried to the cashier's cage by a person who is 

independent of the cage or pit.

(17) The credit slip shall be signed by at least the following persons (as an indication 

that each has counted or, in the case of markers, reviewed the items transferred):

(i) Cashier who received the items transferred from the pit and prepared the credit 

slip;

(ii) Runner who carried the items transferred from the pit to the cage;

(iii) Dealer who had custody of the items prior to transfer to the cage; and

(iv) Pit supervisory personnel who supervised the credit transaction.

(18) The credit slip shall be inserted in the drop box by the dealer.

(19) (13) Chips, tokens, or other cash equivalents shall be deposited on or removed from 

gaming tables only when accompanied by the appropriate fill/credit or marker transfer 

forms. 

(20) (14) Cross fills (the transfer of chips between table games) and even cash exchanges 

are prohibited in the pit. 

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Justification: Revisions are intended to better differentiate the controls pertaining to a 

computerized fill/credit system, to consolidate the fill and credit standards, and to 

recognize that the transfer of markers may also be handled as a credit transaction. 

(d) Table inventory forms. (1) At the close of each shift, for those table banks that were 

opened during that shift: 

Comment (January): We recommend adding language that would inform 

personnel that these controls will apply any time a game is closed during a 

shift by the gaming operation or at the close of each shift. 

Response: Disagree. The procedures are performed at the close of each shift 

for all tables that were open during the shift, regardless of when they closed. 

(i) The table's chip, token, coin, and marker inventory shall be counted and recorded on a 

table inventory form; or 

(ii) If the table banks are maintained on an imprest basis, a final fill or credit shall be 

made to bring the bank back to par. 

(2) If final fills are not made, beginning and ending inventories shall be recorded on the 

master game sheet for shift win calculation purposes. 

Comment (January): We recommend adding the words “on an imprest” basis 

after the word “made”. 

Response: Final fills are not relevant to a floating bank. Agree to modify 

wording for clarity. 

Proposed revision as a result of January comment: 

(2) If final fills are not made the table banks are not maintained on an imprest basis, 

beginning and ending inventories shall be recorded on the master game sheet for shift win 

calculation purposes. 

(3) The accuracy of inventory forms prepared at shift end shall be verified by the 

outgoing pit table games supervisor and the dealer. Alternatively, if the dealer is not 

available, such verification may be provided by another pit table games supervisor or 

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another supervisor from another gaming department. Verifications shall be evidenced by 

signature on the inventory form. 

(4) If inventory forms are placed in the drop box, such action shall be performed by a 

person other than a pit table games supervisor. 

(e) Table games computer generated documentation standards. (1) The computer system 

shall be capable of generating adequate documentation of all information recorded on the 

source documents and transaction detail (e.g., fill/credit slips, markers, etc.). 

(2) This documentation shall be restricted to authorized personnel. 

(3) The documentation shall include, at a minimum: 

(i) System exception information (e.g., appropriate system parameter information, 

corrections, voids, etc.); and 

(ii) Personnel access listing, which includes, at a minimum: 

(A) Employee name or employee identification number (if applicable); and 

(B) Listing of functions employees can perform or equivalent means of identifying the 

same. 

(f) Standards for playing cards and dice. (1) Playing New and used playing cards and 

dice to be issued to a table shall be maintained in a secure location to prevent 

unauthorized access and to reduce the possibility of tampering. 

(2) Used cards and dice that are not to be reused shall be maintained in a secure

location until promptly marked, scored, or destroyed, and removed from service in a 

manner as approved by the Tribal gaming regulatory authority, to prevent 

unauthorized access and reduce the possibility of tampering. 

 Comment (January): What does “promptly” mean. Prone to multiple 

interpretations. 

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Response: Agree. Modified to provide clarity. 

Comment (January): Recommend reinstating requirement to maintain cards in 

a secured location until marked, scored or destroyed. 

Response: Agree. Modified accordingly 

 Comment (January): Aren’t cards removed from service prior to being marked, 

scored or destroyed? 

Response: Agree. Modified accordingly. 

Proposed revision as a result of January comments: 

(2) Used cards and dice that are not to be reused shall be maintained in a secure 

location until promptly marked, scored, or destroyed. Unless otherwise defined by 

Tribal gaming regulatory authority, promptly is a period not to exceed seven (7) 

days. in a manner as approved by the Tribal gaming regulatory authority, to 

prevent unauthorized access and reduce the possibility of tampering. 

(3) 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 a reasonable time period, which shall not exceed seven (7) days, 

within which to mark, cancel, or destroy cards and dice from play.

(i) This standard shall not apply where playing cards or dice are retained for an 

investigation. 

(ii) [Reserved] 

(4) A card control log shall be maintained that documents when cards and dice are 

received on site, distributed to and returned from tables and removed from play by the 

gaming operation. 

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Justification: Revision is intended to recognize that the control is effective only when 

the cards being removed from play are promptly cancelled or destroyed. Additionally, 

revision recognizes that used cards, as management may deem appropriate, may be 

injected back into play. 

(g) Plastic cards. Notwithstanding paragraph (f) of this section, if a gaming 

operation uses plastic cards (not plastic-coated cards), the cards may be used for up 

to three (3) months if the plastic cards are routinely inspected, and washed or 

cleaned in a manner and time frame approved by the Tribal gaming regulatory 

authority.

Justification: Proposed revisions to (f) make the need for plastic card controls 

unwarranted. 

(h) (g) Standards for supervision. Pit Table games supervisory personnel (with 

authority equal to or greater than those being supervised) shall provide supervision of all 

table games. 

(i) (h) Analysis of table game performance standards. (1) Records shall be maintained 

by day and shift indicating any single-deck blackjack games that were dealt for an 

entire shift. 

(2) (1) Records reflecting hold percentage by table and type of game shall be 

maintained by shift, by day, cumulative month-to-date, and cumulative year-todate. A table game statistical analysis report reflecting statistical drop [drop (+) pit 

credit issues (-) pit credit payments in cash], statistical win [table game gross 

revenue (+) marker credits] and statistical win to statistical drop hold percentage by 

table and type of game shall be maintained by shift, by day, cumulative month-todate, and cumulative year-to-date. Promotional activity is not required to be 

tracked and included in the report.

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Comment (January): Are definitions for statistical drop and statistical win 

included in §542.2? 

Response: Yes. 

(3) (2) This information shall be presented to and reviewed by management independent 

of the pit department on at least a monthly basis. At a minimum, the review shall 

consist of the following:

Comment (March): As previously recommended, reference to “pit department” 

should be changed to “table games department.” 

Response: Agreed. Modified accordingly throughout 542.12. 

Proposed revision as a result of March comment: 

(3) (2) This information shall be presented to and reviewed by management independent 

of the pit table games department on at least a monthly basis. At a minimum, the 

review shall consist of the following:

(i) Examination of the information for clerical errors;

(ii) Comparison of the statistical results with the base level statistical performance. 

Base level is defined as either the statistical win to statistical drop hold percentage 

for the most recent calendar year or fiscal year, or a rolling average statistical win 

to statistical drop percentage for the immediately preceding 12 months. 

(4) (3) The management in paragraph (i) (3) of this section shall investigate any 

unusual fluctuations in hold percentage with pit supervisory personnel. (Revised 

May 4, 2005) On a monthly basis, management shall investigate all statistical 

fluctuations by game type from the base level for the month in excess of (+/-) 5%. 

The investigation shall be completed no later than 30 days after the generation of 

the month-end table games analysis report and include information from the pit 

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department, accounting department, surveillance department, cage and credit 

department, and any other relevant department. The report will generally include 

an analysis of the following:

Note: It was specifically noted that although table game statistical analysis 

reports are required to be maintained by table and by game type, investigation 

need only be conducted of fluctuations by game type of +/- 5%. 

Comment (January): Recommend inserting “may” before “include”. 

Response: Agree. Modified accordingly. 

Comment (January): Recommend replacing “pit department” with “table 

games department”. 

Response: Agree. Modified accordingly. 

Proposed revision as a result of January comments: 

(4) (3) The management in paragraph (i) (3) of this section shall investigate any 

unusual fluctuations in hold percentage with pit supervisory personnel. (Revised 

May 4, 2005) On a monthly basis, management shall investigate all statistical 

fluctuations by game type from the base level for the month in excess of (+/-) 5%. 

The investigation shall be completed no later than 30 days after the generation of 

the month-end table games analysis report and may include information from the 

table games department, accounting department, surveillance department, cage and 

credit department, and any other relevant department. The report will generally 

include an analysis of the following:

(i) Drop, win and credit activity of customers whose play materially affected the 

results for the month including the amount of pit credit issued, amount of pit credit 

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paid in cash at the table, the amount of drop from the customer and resulting 

win/loss from the customer;

(ii) Effect of any changes to the rules, types of wagers or game play procedures 

made to accommodate the wagering activity of any customers;

(iii) Effect of any free play or promotional activity utilized during the month;

(iv) Effect of errors or mistakes made during the operation of the game during the 

month;

(v) Any other unusual occurrences during the month being reviewed.

Note: Numbering corrected. 

(4) The results of such investigations shall be documented, maintained for inspection, and 

provided to the Tribal gaming regulatory authority upon request. 

Justification: Revision is proposing to strike the controls specific to a hand dealt game 

since they are no longer warranted. Revision is proposing statistical tracking procedures 

considered to be more effective in the monitoring of game performance. 

542.12 (i) Accounting/auditing standards has been moved to proposed Revenue Audit 

 542.50 (e). 

(i) Accounting/auditing standards. (1) The accounting and auditing procedures shall

be performed by personnel who are independent of the transactions being 

audited/accounted for.

(2) For computerized player tracking systems, an accounting/audit employee shall 

perform the following procedures for at least one day per quarter:

(i) Review all point addition/deletion authorization documentation, other than for 

point additions/deletions made through an automated process, for propriety;

(ii) Review exception reports including transfers between accounts; and

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Comment (January): Recommend inserting the word “point” after 

“including.” 

Response: Agree. Modified accordingly.

Proposed revision as a result of January comment:

(ii) Review exception reports including point transfers between accounts; and

(iii) Review documentation related to access to inactive and closed accounts.

(3) At least annually, the computerized table game player tracking system shall be 

reviewed by personnel independent of the individuals that set up or make changes to 

the system parameters. The review is performed to determine that the configuration 

parameters are accurate and have not been altered without appropriate 

management authorization (e.g., verify the accuracy of the awarding of points based 

on the dollar amount wagered). The system should also be tested, if possible, to 

further verify the accuracy of the configuration parameters (e.g., simulate activity to 

verify the accuracy of the amount of points awarded). The test results shall be 

documented and maintained for Tribal gaming regulatory authority review upon 

request.

Comment (January): Typically, this is a function not accessible to Table 

Games personnel. This is an IT function. Should this not appear in the IT 

section?

Response: Disagree. Typically this function would be performed by 

Internal Audit or Revenue Audit.

(4) The following procedures shall be performed on fill/credit slips and marker 

credit slips by accounting/audit personnel:

(i) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, reconcile the original slip (placed in the table game drop box) to the 

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restricted copy to verify that the dollar amount of the transaction is the same on 

both parts of the slip.

(ii) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, verify that all numerically numbered slips issued are properly accounted 

for. Investigations shall be performed for all slips that are unaccounted for with the 

investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(iii) For at least one day per month, foot (add up) the original slips (placed in the 

table game drop box) and trace the total to the total fill/credit and marker credit 

amounts indicated on the master game summary prepared by the count team 

members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iv) For each day, examine a sample of slips for propriety of signatures and proper 

completion.

(5) The following procedures shall be performed on marker issue/payment slips by 

accounting/audit personnel:

(i) For manual marker issue slips, for at least one day each month, verify that all 

numerically numbered slips are properly accounted for. Investigations shall be 

performed for all slips that are unaccounted for with the investigation being 

documented and retained for Tribal gaming regulatory authority review upon 

request.

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(ii) For at least one day per month, foot (add up) the marker issue and payment slips 

(placed in the table game drop box) and trace the total to the total marker issue and 

payment amounts indicated on the master games summary prepared by the count 

team members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iii) For each day, examine a sample of marker issue and payment slips for 

propriety of signatures and proper completion.

(iv) If count team members only totaled marker issue and payment slips by shift and 

traced to the totals documented by the computer system, for each day, verify that 

the issue/payment slips for each table are accurate.

(6) For each day, accounting/audit personnel shall reconcile the total dollar amount 

of markers transferred as indicated on the mass marker transfer form(s) and 

marker credit slips to the dollar amount recorded on the cage accountability 

documentation. The mass marker transfer form shall be reviewed for propriety of 

signatures and proper completion.

(7) The following procedures shall be performed on voided markers and voided 

fill/credit slips by accounting/audit personnel (accounting/audit department 

employees who are soft count team members may perform) after the soft count 

process for each day:

(i) Examine all voided forms for proper authorization and “void” designation;

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(ii) For fill/credit and marker computer systems, trace the voided form to computer 

system report(s) reflecting void activity;

(iii) For fill/credit and marker computer systems, examine the computer system 

report(s) reflecting void activity for void transactions that are not supported by a 

voided form.

(iv) Determine that all parts of the voided form have been received.

Comment (January): Is (iv) above referring to receipt by Accounting?

Response: Yes.

(v) Examine form for the proper number of signatures.

(vi) For all voided markers, determine that the void of the pit marker was not 

performed by cage personnel and compare the time of marker issuance to the time 

of voiding to determine that transactions were voided within 30 minutes after the 

issuance of the marker. If not voided within 30 minutes, determine whether the 

documented reason for exceeding the time period is adequate.

(8) The following procedures shall be performed on rim credit cards by 

accounting/audit personnel each day:

(i) Verify that all numerically numbered rim cards are properly accounted for. 

Investigations shall be performed for all forms that are unaccounted for with the 

investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(ii) Examine a sample of rim cards for propriety of signatures and proper 

completion.

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(iii) Foot (add up) balance increases/decreases of rim credit to ensure clerical 

accuracy of the outstanding rim credit balance.

(iv) For rim cards in which the outstanding rim credit balance has been reduced to 

zero by a transaction other than a transfer to another table or shift, verify that the 

rim credit was reduced by the issuance of a marker or paid in full by the customer 

within seven days from the last date of recorded customer rim activity by reviewing 

the customer’s rim card(s) for the last date of the prior increase/decrease to the rim 

credit balance and comparing it to the final date of the rim credit balance was 

reduced to zero.

Comment (January): Please provide clarification of this standard. Does this 

provide for rim credit to be open for seven days or must rim credit be 

converted into a marker that must be paid within seven (7) days? 

Response: Rim credit cards must be paid in full or replaced with a marker 

within seven days from the last date of recorded customer rim activity. 

Modified wording to clarify.

Proposed revision as a result of January comment:

(iv) For rim cards in which the outstanding rim credit balance has been reduced to 

zero by a transaction other than a transfer to another table or shift, verify that the 

rim credit was reduced by the issuance of a marker or paid in full by the customer 

within seven days from the last date of recorded customer rim activity, as required 

by 542.12 (n) (4), by reviewing the customer’s rim card(s) for the last date of the 

prior increase/decrease to the rim credit balance and comparing it to the final date 

of the rim credit balance was reduced to zero.

(v) Determine if any issued markers used to reduce the rim credit balance were 

subsequently voided and rim credit improperly reopened.

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(vi) For transfer of rim credit balances to another table or shift, verify that the 

amount transferred traces from one table’s/shift’s rim card to the other 

table’s/shift’s rim card.

(9) The following procedures shall be performed by accounting/auditing personnel 

using the master game summary prepared by the count team members for each 

day:

(i) Reconcile the dollar amount of currency drop proceeds on the master games

summary to the dollar amount recorded in the applicable accountability document 

using, if applicable, the transfer forms indicating all transfers in/out of the currency 

count room, both during and at the end of the count. Investigate and document any 

variance noted.

(ii) Recalculate win/loss in total and by shift. For computerized master game 

summaries that compute win/loss, accounting personnel shall recalculate win/loss in 

total and by shift for at least one day each month, rather than daily.

Comment (January): Recommend striking “rather than daily” from the 

end of the standard.

Response: Qualifying language will be moved and restated for clarity. 

Modified accordingly.

Proposed revision as a result of January comment:

(ii) Recalculate win/loss in total and by shift on a daily basis. For computerized 

master game summaries that compute win/loss, accounting personnel shall 

recalculate win/loss in total and by shift for at least one day each month. 

Comment (January): Recommend separating (ii) into (ii) and (iii) and 

renumbering balance.

Response: Agreed. Modified accordingly.

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Proposed revision as a result of January comment:

(ii) Recalculate win/loss in total and by shift on a daily basis. 

(iii) For computerized master game summaries that compute win/loss, accounting 

personnel shall recalculate win/loss in total and by shift for at least one day each 

month. 

(iv) Verify that the correct total of win/loss on the master games summary is 

recorded in the accounting records.

(v) Examine documents for propriety of signatures.

(2) (10) If a table game has the capability to determine drop (e.g., bill-in/coin-drop 

meters, bill acceptor, computerized record, etc.) the dollar amount of the drop shall 

be reconciled to the actual drop by shift. Follow-up shall be performed for each 

table having an unresolved variance in excess of $200 between actual cash and the 

automated recordings. The follow-up performed by accounting/auditing personnel 

and results of investigation shall be documented and maintained for Tribal gaming 

regulatory authority review upon request.

Comment (January): Recommend substituting “investigation” for “followup”.

Response: Agreed. Modified accordingly.

Proposed revision as a result of January comment:

(2) (10) If a table game has the capability to determine drop (e.g., bill-in/coin-drop 

meters, bill acceptor, computerized record, etc.) the dollar amount of the drop shall 

be reconciled to the actual drop by shift. An investigation shall be performed for 

each table having an unresolved variance in excess of $200 between actual cash and 

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the automated recordings. The investigation performed by accounting/auditing 

personnel and results of investigation shall be documented and maintained for 

Tribal gaming regulatory authority review upon request.

(3) (11) Accounting/auditing employees shall review exception reports for all 

computerized table games systems at least monthly for propriety of transactions and 

unusual occurrences. The review shall include, but not be limited to, void 

authorizations. 

(4) (12) All noted improper transactions or unusual occurrences shall be 

investigated with the results documented and maintained for Tribal gaming 

regulatory authority review upon request.

(13) For all contests, tournaments, promotional payouts (including payouts from 

computerized player tracking activity), drawings, and giveaway programs, the 

following documentation is required to be maintained:

Comment (January): There is not time period specified for retention.

Response: Agree. Will modify to indicate that the gaming operation, 

subject to the approval of the Tribal gaming regulatory authority, shall 

establish a reasonable time period during which the documentation shall be 

maintained.

Proposed revision as a result of January comment:

(13) For all contests, tournaments, promotional payouts (including payouts from 

computerized player tracking activity), drawings, and giveaway programs, the 

following documentation is required to be maintained for a reasonable time period 

as established by the gaming operation and approved by the Tribal gaming 

regulatory authority:

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(i) Copies of the information provided to the customers describing the contests, 

tournaments, promotional payouts, drawings, and giveaway programs (e.g., 

brochures, fliers);

(ii) Effective dates and;

(iii) Accounting treatment, including general ledger accounts, if applicable.

(iv) For tournaments and contests, the name of the organizations (or persons) that 

conducted the contest/tournament on behalf of, or in conjunction with, the gaming 

operation, if any. The extent of responsibilities each organization and the gaming 

operation had in the contest/tournament (e.g., nonprofit receives 100% of the entry 

fees and provides noncash prizes to the winners with the gaming operation being 

responsible for collecting the entry fees, dealing the tournament and distributing 

prizes to winners) shall also be documented.

Comment (January): Is this referring to written agreements with third 

parties?

Response: Yes. The purpose of this requirement is to determine the 

appropriate accounting treatment.

 

Comment (January): Please provide clarification on what impact this 

standard will have on non-house banked table games and if it does apply 

what are the requirements for complying with this standard. 

Response: NIGC’s Office of General Counsel (OGC) has opined that 

Blackjack, regardless of how it is played, is a Class III game. Furthermore, 

non-house banked Blackjack is not a contest, which generally start and end 

within a relatively short period of time. Therefore, this standard has no 

applicability to non-house banked Blackjack.

(14) At least monthly, accounting/auditing personnel shall review all contests, 

tournaments, promotional payouts, drawings, and giveaway programs to confirm 

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proper accounting treatment and proper table games gross revenue win/loss 

computation.

Comment (January): Recommend adding the words “table games” after 

“all”. A similar change was made in the proposed gaming machine section.

Response: Agree. Revised accordingly.

Proposed revision as a result of January comment:

(14) At least monthly, accounting/auditing personnel shall review all table games 

contests, tournaments, promotional payouts, drawings, and giveaway programs to 

confirm proper accounting treatment and proper table games gross revenue 

win/loss computation.

Comment (January): Recommend allowing for a sample in this standard. 

Response: The purpose of the standard is to verify that they were recorded 

correctly in the general ledger. Would anticipate that there would be only 

a handful of them.

Comment (January): In Oklahoma that is not the case. There are a lot of 

contests, tournaments, etc.

Response: It is not unreasonable to assume that the same type of contest, 

tournament, etc. would be accounted for in the same manner. Therefore, 

suggest the following: “At least monthly, accounting/auditing personnel 

shall perform procedures to reasonably ensure that table games contests, 

tournaments, promotional payouts, drawings, and giveaway programs are 

afforded proper accounting treatment.” Modified accordingly.

Proposed revision as a result of January comments:

(14) At least monthly, accounting/auditing personnel shall perform procedures to 

reasonably ensure that table games contests, tournaments, promotional payouts, 

drawings, and giveaway programs are afforded proper accounting treatment.

(15) At least monthly, accounting/auditing personnel shall perform procedures to 

ensure that promotional payouts, drawings, and giveaway programs are conducted 

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in accordance with the conditions provided the public. The procedures shall include 

a review of documents as well as employee interviews and/or observations.

Comment (January): A lengthy discussion regarding the assertions that 

employee interviews and/or observations were not an appropriate nor 

desirable activity for accounting/auditing personnel and that those types of 

activities were more in the nature of an investigation, which is more 

appropriately a regulatory activity.

Response: As a result of the concerns raised, the proposed requirement 

will be deleted and subsequent items renumbered accordingly. Modified 

accordingly.

(15) At least monthly, accounting/auditing personnel shall perform procedures to 

ensure that promotional payouts, drawings, and giveaway programs are conducted 

in accordance with the conditions provided the public. The procedures shall include 

a review of documents as well as employee interviews and/or observations.

(15) Daily, accounting/audit personnel shall reconcile all contest/tournament entry 

and payout forms to the dollar amounts recorded in the appropriate accountability 

document.

(16) When payment is made to the winners of a contest/tournament, 

accounting/audit personnel shall reconcile the contest/tournament entry fees 

collected to the actual contest/tournament payouts made. This reconciliation is to 

determine whether, based on the entry fees collected, the payouts made and 

amounts withheld by the gaming operation, if applicable, were distributed in 

accordance with the contest/tournament rules.

(5) (17) Evidence of table games auditing procedures and any follow-up performed 

shall be documented, maintained for inspection, and provided to the Tribal gaming 

regulatory authority upon request.

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(6) (18) A daily recap shall be prepared for the day and month-to-date, which shall 

include the following information:

(i) Drop;

(ii) Win; and

(iii) Gross revenue.

(19) Monthly, accounting/auditing personnel shall reconcile gross revenue from the 

general ledger to the month-end daily tables games recap. 

Justification: Revisions expand the scope of the accounting and auditing standards 

to address the testing of player tracking systems, fill/credit issues and marker 

issuances/payments/voids and transfers, rim credit transactions, game results, drop 

variances, and contest/tournaments/promotional drawings and giveaway programs. 

It is noteworthy that the section has not been materially revised since 2002.

Comment (January): Recommend separating/rearranging those items that 

pertain to table games contests/tournaments, etc. from those that pertain to 

table games themselves. 

Response: Agreed. Modified accordingly. 

Proposed revision as a result of January comment:

(1) The accounting and auditing procedures shall be performed by personnel who 

are independent of the transactions being audited/accounted for.

(5) (2) Evidence of table games auditing procedures and any follow-up performed 

shall be documented, maintained for inspection, and provided to the Tribal gaming 

regulatory authority upon request.

(6) (3) A daily recap shall be prepared for the day and month-to-date, which shall 

include the following information:

(i) Drop;

(ii) Win; and

7-8-10 Version 

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(iii) Gross revenue.

(4) Monthly, accounting/auditing personnel shall reconcile gross revenue from the 

general ledger to the month-end daily tables games recap. 

(5) The following procedures shall be performed by accounting/auditing personnel 

using the master game summary prepared by the count team members for each 

day:

(i) Reconcile the dollar amount of currency drop proceeds on the master games 

summary to the dollar amount recorded in the applicable accountability document 

using, if applicable, the transfer forms indicating all transfers in/out of the currency 

count room, both during and at the end of the count. Investigate and document any 

variance noted.

(ii) Recalculate win/loss in total and by shift on a daily basis. 

(iii) For computerized master game summaries that compute win/loss, accounting 

personnel shall recalculate win/loss in total and by shift for at least one day each 

month. 

(iv) Verify that the correct total of win/loss on the master games summary is 

recorded in the accounting records.

(v) Examine documents for propriety of signatures.

(2) (6) If a table game has the capability to determine drop (e.g., bill-in/coin-drop 

meters, bill acceptor, computerized record, etc.) the dollar amount of the drop shall 

be reconciled to the actual drop by shift. An investigation shall be performed for 

each table having an unresolved variance in excess of $200 between actual cash and 

the automated recordings. The investigation performed by accounting/auditing 

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personnel and results of investigation shall be documented and maintained for 

Tribal gaming regulatory authority review upon request.

(3) (7) Accounting/auditing employees shall review exception reports for all 

computerized table games systems at least monthly for propriety of transactions and 

unusual occurrences. The review shall include, but not be limited to, void 

authorizations. 

(4) (8) All noted improper transactions or unusual occurrences shall be investigated 

with the results documented and maintained for Tribal gaming regulatory authority 

review upon request.

(9) For computerized player tracking systems, an accounting/audit employee shall 

perform the following procedures for at least one day per quarter:

(i) Review all point addition/deletion authorization documentation, other than for 

point addition/deletions made through an automated process, for propriety;

(ii) Review exception reports including point transfers between accounts; and

(iii) Review documentation related to access to inactive and closed accounts.

(10) At least annually, the computerized table game player tracking system shall be 

reviewed by personnel independent of the individuals that set up or make changes to 

the system parameters. The review is performed to determine that the configuration 

parameters are accurate and have not been altered without appropriate 

management authorization (e.g., verify the accuracy of the awarding of points based 

on the dollar amount wagered). The system should also be tested, if possible, to 

further verify the accuracy of the configuration parameters (e.g., simulate activity to 

verify the accuracy of the amount of points awarded). The test results shall be 

7-8-10 Version 

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documented and maintained for Tribal gaming regulatory authority review upon 

request.

(11) The following procedures shall be performed on fill/credit slips and marker 

credit slips by accounting/audit personnel:

(i) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, reconcile the original slip (placed in the table game drop box) to the 

restricted copy to verify that the dollar amount of the transaction is the same on 

both parts of the slip.

(ii) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, verify that all numerically numbered slips issued are properly accounted 

for. Investigations shall be performed for all slips that are unaccounted for with the 

investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(iii) For at least one day per month, foot (add up) the original slips (placed in the 

table game drop box) and trace the total to the total fill/credit and marker credit 

amounts indicated on the master game summary prepared by the count team 

members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iv) For each day, examine a sample of slips for propriety of signatures and proper 

completion.

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(12) The following procedures shall be performed on marker issue/payment slips by 

accounting/audit personnel:

(i) For manual marker issue slips, for at least one day each month, verify that all 

numerically numbered slips are properly accounted for. Investigations shall be 

performed for all slips that are unaccounted for with the investigation being 

documented and retained for Tribal gaming regulatory authority review upon 

request.

(ii) For at least one day per month, foot (add up) the marker issue and payment slips 

(placed in the table game drop box) and trace the total to the total marker issue and 

payment amounts indicated on the master games summary prepared by the count 

team members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iii) For each day, examine a sample of marker issue and payment slips for 

propriety of signatures and proper completion.

(iv) If count team members only totaled marker issue and payment slips by shift and 

traced to the totals documented by the computer system, for each day, verify that 

the issue/payment slips for each table are accurate.

(13) For each day, accounting/audit personnel shall reconcile the total dollar amount 

of markers transferred as indicated on the mass marker transfer form(s) and 

marker credit slips to the dollar amount recorded on the cage accountability 

7-8-10 Version 

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documentation. The mass marker transfer form shall be reviewed for propriety of 

signatures and proper completion.

(14) The following procedures shall be performed on voided markers and voided 

fill/credit slips by accounting/audit personnel (accounting/audit department 

employees who are soft count team members may perform) after the soft count 

process for each day:

(i) Examine all voided forms for proper authorization and “void” designation;

(ii) For fill/credit and marker computer systems, trace the voided form to computer 

system report(s) reflecting void activity;

(iii) For fill/credit and marker computer systems, examine the computer system 

report(s) reflecting void activity for void transactions that are not supported by a 

voided form.

(iv) Determine that all parts of the voided form have been received.

(v) Examine form for the proper number of signatures.

(vi) For all voided markers, determine that the void of the pit marker was not 

performed by cage personnel and compare the time of marker issuance to the time 

of voiding to determine that transactions were voided within 30 minutes after the 

issuance of the marker. If not voided within 30 minutes, determine whether the 

documented reason for exceeding the time period is adequate.

(15) The following procedures shall be performed on rim credit cards by 

accounting/audit personnel each day:

(i) Verify that all numerically numbered rim cards are properly accounted for. 

Investigations shall be performed for all forms that are unaccounted for with the 

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investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(ii) Examine a sample of rim cards for propriety of signatures and proper 

completion.

(iii) Foot (add up) balance increases/decreases of rim credit to ensure clerical 

accuracy of the outstanding rim credit balance.

(iv) For rim cards in which the outstanding rim credit balance has been reduced to 

zero by a transaction other than a transfer to another table or shift, verify that the 

rim credit was reduced by the issuance of a marker or paid in full by the customer 

within seven days from the last date of recorded customer rim activity, as required 

by 542.12 (n) (4), by reviewing the customer’s rim card(s) for the last date of the 

prior increase/decrease to the rim credit balance and comparing it to the final date 

of the rim credit balance was reduced to zero.

(v) Determine if any issued markers used to reduce the rim credit balance were 

subsequently voided and rim credit improperly reopened.

(vi) For transfer of rim credit balances to another table or shift, verify that the 

amount transferred traces from one table’s/shift’s rim card to the other 

table’s/shift’s rim card.

(16) For all contests, tournaments, drawings, and giveaway programs, the following 

documentation is required to be maintained:

(i) Copies of the information provided to the customers describing the contests, 

tournaments, drawings, and giveaway programs (e.g., brochures, fliers);

(ii) Effective dates and;

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(iii) Accounting treatment, including general ledger accounts, if applicable.

(iv) For tournaments and contests, the name of the organizations (or persons) that 

conducted the contest/tournament on behalf of, or in conjunction with, the gaming 

operation, if any. The extent of responsibilities each organization and the gaming 

operation had in the contest/tournament (e.g., nonprofit receives 100% of the entry 

fees and provides noncash prizes to the winners with the gaming operation being 

responsible for collecting the entry fees, dealing the tournament and distributing 

prizes to winners) shall also be documented.

(17) At least monthly, accounting/auditing personnel shall review all contests, 

tournaments, drawings, and giveaway programs to confirm proper accounting 

treatment and proper table games gross revenue win/loss computation.

(18) Daily, accounting/audit personnel shall reconcile all contest/tournament entry 

and payout forms to the dollar amounts recorded in the appropriate accountability 

document.

(19) When payment is made to the winners of a contest/tournament, 

accounting/audit personnel shall reconcile the contest/tournament entry fees 

collected to the actual contest/tournament payouts made. This reconciliation is to 

determine whether, based on the entry fees collected, the payouts made and 

amounts withheld by the gaming operation, if applicable, were distributed in 

accordance with the contest/tournament rules.

(1) The accounting and auditing procedures shall be performed by personnel who 

are independent of the transactions being audited/accounted for.

7-8-10 Version 

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(2) Evidence of table games auditing procedures and any follow-up performed shall 

be documented, maintained for inspection, and provided to the Tribal gaming 

regulatory authority upon request.

(3) A daily recap shall be prepared for the day and month-to-date, which shall 

include the following information:

(i) Drop;

(ii) Win; and

(iii) Gross revenue.

(4) Monthly, accounting/auditing personnel shall reconcile gross revenue from the 

general ledger to the month-end daily tables games recap. 

(5) The following procedures shall be performed by accounting/auditing personnel 

using the master game summary prepared by the count team members for each 

day:

(i) Reconcile the dollar amount of currency drop proceeds on the master games 

summary to the dollar amount recorded in the applicable accountability document 

using, if applicable, the transfer forms indicating all transfers in/out of the currency 

count room, both during and at the end of the count. Investigate and document any 

variance noted.

(ii) Recalculate win/loss in total and by shift on a daily basis. 

(iii) For computerized master game summaries that compute win/loss, accounting 

personnel shall recalculate win/loss in total and by shift for at least one day each 

month. 

7-8-10 Version 

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(iv) Verify that the correct total of win/loss on the master games summary is 

recorded in the accounting records.

(v) Examine documents for propriety of signatures.

(6) If a table game has the capability to determine drop (e.g., bill-in/coin-drop 

meters, bill acceptor, computerized record, etc.) the dollar amount of the drop shall 

be reconciled to the actual drop by shift. An investigation shall be performed for 

each table having an unresolved variance in excess of $200 between actual cash and 

the automated recordings. The investigation performed by accounting/auditing 

personnel and results of investigation shall be documented and maintained for 

Tribal gaming regulatory authority review upon request.

(7) Accounting/auditing employees shall review exception reports for all 

computerized table games systems at least monthly for propriety of transactions and 

unusual occurrences. The review shall include, but not be limited to, void 

authorizations. 

(8) All noted improper transactions or unusual occurrences shall be investigated 

with the results documented and maintained for Tribal gaming regulatory authority 

review upon request.

(9) For computerized player tracking systems, an accounting/audit employee shall 

perform the following procedures for at least one day per quarter:

(i) Review all point addition/deletion authorization documentation, other than for 

point addition/deletions made through an automated process, for propriety;

(ii) Review exception reports including point transfers between accounts; and

(iii) Review documentation related to access to inactive and closed accounts.

7-8-10 Version 

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(10) At least annually, the computerized table game player tracking system shall be

reviewed by personnel independent of the individuals that set up or make changes to 

the system parameters. The review is performed to determine that the configuration 

parameters are accurate and have not been altered without appropriate 

management authorization (e.g., verify the accuracy of the awarding of points based 

on the dollar amount wagered). The system should also be tested, if possible, to 

further verify the accuracy of the configuration parameters (e.g., simulate activity to 

verify the accuracy of the amount of points awarded). The test results shall be 

documented and maintained for Tribal gaming regulatory authority review upon 

request.

(11) The following procedures shall be performed on fill/credit slips and marker 

credit slips by accounting/audit personnel:

(i) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, reconcile the original slip (placed in the table game drop box) to the 

restricted copy to verify that the dollar amount of the transaction is the same on 

both parts of the slip.

(ii) For manual fill/credit slips and manual marker credit slips, for at least one day 

per month, verify that all numerically numbered slips issued are properly accounted 

for. Investigations shall be performed for all slips that are unaccounted for with the 

investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(iii) For at least one day per month, foot (add up) the original slips (placed in the 

table game drop box) and trace the total to the total fill/credit and marker credit 

7-8-10 Version 

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amounts indicated on the master game summary prepared by the count team 

members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iv) For each day, examine a sample of slips for propriety of signatures and proper 

completion.

(12) The following procedures shall be performed on marker issue/payment slips by 

accounting/audit personnel:

(i) For manual marker issue slips, for at least one day each month, verify that all 

numerically numbered slips are properly accounted for. Investigations shall be 

performed for all slips that are unaccounted for with the investigation being 

documented and retained for Tribal gaming regulatory authority review upon 

request.

(ii) For at least one day per month, foot (add up) the marker issue and payment slips 

(placed in the table game drop box) and trace the total to the total marker issue and 

payment amounts indicated on the master games summary prepared by the count 

team members. If the reconciliation results in a variance, an investigation shall be 

performed to determine whether all forms are accounted for with the investigation 

being documented and retained for Tribal gaming regulatory authority review upon 

request.

(iii) For each day, examine a sample of marker issue and payment slips for 

propriety of signatures and proper completion.

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(iv) If count team members only totaled marker issue and payment slips by shift and 

traced to the totals documented by the computer system, for each day, verify that 

the issue/payment slips for each table are accurate.

(13) For each day, accounting/audit personnel shall reconcile the total dollar amount 

of markers transferred as indicated on the mass marker transfer form(s) and 

marker credit slips to the dollar amount recorded on the cage accountability 

documentation. The mass marker transfer form shall be reviewed for propriety of 

signatures and proper completion.

(14) The following procedures shall be performed on voided markers and voided 

fill/credit slips by accounting/audit personnel (accounting/audit department 

employees who are soft count team members may perform) after the soft count 

process for each day:

(i) Examine all voided forms for proper authorization and “void” designation;

(ii) For fill/credit and marker computer systems, trace the voided form to computer 

system report(s) reflecting void activity;

(iii) For fill/credit and marker computer systems, examine the computer system 

report(s) reflecting void activity for void transactions that are not supported by a 

voided form.

(iv) Determine that all parts of the voided form have been received.

(v) Examine form for the proper number of signatures.

(vi) For all voided markers, determine that the void of the pit marker was not 

performed by cage personnel and compare the time of marker issuance to the time 

of voiding to determine that transactions were voided within 30 minutes after the 

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issuance of the marker. If not voided within 30 minutes, determine whether the 

documented reason for exceeding the time period is adequate.

(15) The following procedures shall be performed on rim credit cards by 

accounting/audit personnel each day:

(i) Verify that all numerically numbered rim cards are properly accounted for. 

Investigations shall be performed for all forms that are unaccounted for with the 

investigation being documented and retained for Tribal gaming regulatory 

authority review upon request.

(ii) Examine a sample of rim cards for propriety of signatures and proper 

completion.

(iii) Foot (add up) balance increases/decreases of rim credit to ensure clerical 

accuracy of the outstanding rim credit balance.

(iv) For rim cards in which the outstanding rim credit balance has been reduced to 

zero by a transaction other than a transfer to another table or shift, verify that the 

rim credit was reduced by the issuance of a marker or paid in full by the customer

within seven days from the last date of recorded customer rim activity, as required 

by 542.12 (n) (4), by reviewing the customer’s rim card(s) for the last date of the 

prior increase/decrease to the rim credit balance and comparing it to the final date 

of the rim credit balance was reduced to zero.

(v) Determine if any issued markers used to reduce the rim credit balance were 

subsequently voided and rim credit improperly reopened.

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(vi) For transfer of rim credit balances to another table or shift, verify that the 

amount transferred traces from one table’s/shift’s rim card to the other 

table’s/shift’s rim card.

(16) For all contests, tournaments, drawings, and giveaway programs, the following 

documentation is required to be maintained:

(i) Copies of the information provided to the customers describing the contests, 

tournaments, drawings, and giveaway programs (e.g., brochures, fliers);

(ii) Effective dates and;

(iii) Accounting treatment, including general ledger accounts, if applicable.

(iv) For tournaments and contests, the name of the organizations (or persons) that 

conducted the contest/tournament on behalf of, or in conjunction with, the gaming 

operation, if any. The extent of responsibilities each organization and the gaming 

operation had in the contest/tournament (e.g., nonprofit receives 100% of the entry 

fees and provides noncash prizes to the winners with the gaming operation being 

responsible for collecting the entry fees, dealing the tournament and distributing 

prizes to winners) shall also be documented.

(17) At least monthly, accounting/auditing personnel shall review all contests, 

tournaments, drawings, and giveaway programs to confirm proper accounting 

treatment and proper table games gross revenue win/loss computation.

(18) Daily, accounting/audit personnel shall reconcile all contest/tournament entry 

and payout forms to the dollar amounts recorded in the appropriate accountability 

document.

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(19) When payment is made to the winners of a contest/tournament, 

accounting/audit personnel shall reconcile the contest/tournament entry fees 

collected to the actual contest/tournament payouts made. This reconciliation is to 

determine whether, based on the entry fees collected, the payouts made and 

amounts withheld by the gaming operation, if applicable, were distributed in 

accordance with the contest/tournament rules.

(k) (i) Marker credit play. (1) If a gaming operation allows marker credit play (exclusive 

of rim credit and call bets), the following standards shall apply: 

(i) A marker system shall allow for credit to be both issued and repaid in the pit.

Justification: Revision is intended to allow greater latitude to management whether to 

allow the repayment of a marker at the pit or require repayments to occur at the cage. 

(ii) (i) Prior to the issuance of gaming credit to a player, the employee extending the 

credit shall contact the cashier or other independent source to determine if the player's 

credit limit has been properly established and there is sufficient remaining credit 

available for the advance. 

(ii) Unless otherwise known to the employee extending the credit and the personal 

identification information of the player is on file with the gaming operation, verify 

the customer’s identity by examining the customer’s identification credential or 

other reasonable method to ensure the customer’s identity. A customer’s driver’s 

license is the preferred method for verifying the customer’s identity. A passport, 

non-resident alien identification card, other government issued identification 

credential or other picture identification credential normally acceptable as a means 

of identification when cashing checks, may also be used. Subject to approval of the 

Tribal gaming regulatory authority, tribal identifications may be acceptable.

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Comment (January): Recommend adding the word “membership” after tribal to 

distinguish a tribal membership ID from any other kind of tribal ID (e.g. 

employee ID) 

Response: Agreed. Modified accordingly. All references to “tribal identification” 

will be modified as well. 

Proposed revision as a result of January comment: 

(ii) Unless otherwise known to the employee extending the credit and the personal 

identification information of the player is on file with the gaming operation, verify 

the customer’s identity by examining the customer’s identification credential or 

other reasonable method to ensure the customer’s identity. A customer’s driver’s 

license is the preferred method for verifying the customer’s identity. A passport, 

non-resident alien identification card, other government issued identification 

credential or other picture identification credential normally acceptable as a means 

of identification when cashing checks, may also be used. Subject to approval of the 

Tribal gaming regulatory authority, tribal membership identifications may be 

acceptable.

(A) To mitigate the risk of identity theft, it is recommended that, within the 

customer records of the gaming operation, a scanned copy of a picture identification 

and signature be obtained and stored.

(B) [Reserved]

Justification: Revision is intended to require the employee extending credit to confirm 

the identity of the customer credit is being extended, unless that customer is already 

known to the employee and the necessary information is already on file with the gaming 

operation. Furthermore, requirements are being established for acceptable identification 

documents. 

Comment (January): This language currently reads as a recommendation and 

should be revised to read as a standard. 

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Response: Rather than requiring gaming operations to maintain a picture of the 

customer, agree to strike the proposed standard. Modified accordingly. 

Proposed revision as a result of January comment: 

(A) To mitigate the risk of identity theft, it is recommended that, within the 

customer records of the gaming operation, a scanned copy of a picture identification 

and signature be obtained and stored.

(B) [Reserved]

(iii) Proper authorization of credit extension in excess of the previously established limit 

shall be documented. 

(iv) The amount of credit extended shall be communicated to the cage or another 

independent source and the amount documented within a reasonable time subsequent to 

each issuance. 

(v) The marker form shall be prepared in at least triplicate form (triplicate form being 

defined as three parts performing the functions delineated in the standard in paragraph (k) 

(1) (vi) of this section), with a preprinted or concurrently-printed marker number, and 

utilized in numerical sequence. (This requirement shall not preclude the distribution of 

batches of markers to various pits.) (Revised May 4, 2005) 

(vi) At least three parts of each separately numbered marker form shall be utilized as 

follows: 

(A) Original, the negotiable instrument, shall be maintained in the pit until settled paid

or transferred to the cage; 

(B) Payment slip shall be maintained in the pit until the marker is settled paid or 

transferred to the cage. If paid in the pit, the slip shall be inserted in the table game drop 

box. If not paid in the pit, the slip shall be transferred to the cage with the original. 

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Payment slips are not required if all markers are immediately transferred to the 

cage upon issuance, resulting in payments in the pit being precluded; 

(C) Issue slip shall be inserted into the appropriate table game drop box when credit is 

extended or when the player has signed the original. 

Justification: Revisions are intended to add clarity regarding the marker documentation 

requirements, particularly payment slips. 

(vii) When marker documentation (e.g., issue slip and payment slip) is inserted in the 

drop box, such action shall be performed by the dealer or boxperson at the table. 

(viii) A record of each customer’s credit activity shall be maintained that details the 

following (e.g., master credit record retained at the pit podium): 

(A) The signature or initials name or other identifier of the person(s) approving the 

extension of credit (unless such information is contained elsewhere for each 

issuance); 

(B) The legible name of the person receiving the credit; 

(C) The date and shift time of granting the credit; 

(D) The table on which number where the credit was extended; 

(E) The amount of credit issued; 

(F) The marker number; 

(G) The amount of credit remaining after each issuance or the total credit available for all 

issuances; 

(H) The amount of payment received and nature of settlement payment (e.g., credit slip 

number, cash, chips, etc.) or, if transferred to the cage, the marker credit slip or 

mass marker transfer form number; and 

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(I) The signature or initials name or other identifier of the person receiving 

payment/settlement. 

Justification: Revisions are intended to provide better clarity and consistency in the 

regulation governing the collection of information specific to the issuance of markers. 

(ix) The forms required in paragraphs (k) (1) (v), (vi), and (viii) of this section shall be 

safeguarded, and adequate procedures shall be employed to control the distribution, use, 

and access to these forms. All portions of the markers, both issued and unissued, 

shall be safeguarded and procedures shall be employed to control the distribution, 

use and access to the forms. 

Justification: Revision is intended to extend the required controls over the record of 

marker transactions to the individual marker forms. 

Comment (January): The proposed addition to (ix) is already contained in 

(xxiv). Recommend striking. 

Response: Agree. Modified accordingly. 

Proposed revision as a result of January comment: 

(ix) The forms required in paragraphs (k) (1) (v), (vi), and (viii) of this section shall be 

safeguarded, and adequate procedures shall be employed to control the distribution, use, 

and access to these forms. (Revised May 4, 2005) 

(x) All credit extensions shall be initially evidenced by lammer buttons, which shall be 

displayed on the table in public view and placed there by supervisory personnel. 

(xi) Marker preparation shall be initiated and other records updated within approximately 

one hand of play following the initial issuance of credit to the player. Marker 

preparation shall be completed (i.e., dealer signs and drops the issue slip) no later 

than thirty minutes after the chips are given to the customer unless the reason for 

exceeding the time period is documented.

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Justification: Revision is intended to establish minimum requirements that the marker 

be created within a specified time after the chips have been provided to the customer, or 

justification for the delay documented. 

(xii) Lammer buttons shall be removed only by the dealer or boxperson employed at 

the table upon completion of a marker transaction. Only the dealer or boxperson 

may move the lammer buttons from the table into the table tray/inventory, or move 

the lammer buttons to a neutral area for subsequent removal by pit supervisory 

personnel. This procedure shall be performed when the marker slip is placed in the 

table game drop box.

Justification: Revision is intended to add clarity to the standing and to identify 

acceptable alternative procedures for management. 

(xiii) The original marker shall contain at least the following information: 

(A) Marker number; 

(B) Player's name and signature; 

(C) Date; and 

(D) Amount of credit issued. 

(xiv) The issue slip or stub shall include the same marker number as the original, the 

table number, date and time of issuance, and amount of credit issued. The issue slip or 

stub shall also include the signature of the person extending the credit, and the signature 

or initials of the dealer or boxperson at the applicable table, unless this information is 

included on another document verifying the issued marker. 

(xv) The payment slip shall include the same marker number as the original. When the 

marker is paid in full in the pit, it shall also include the table number where paid, date and 

time of payment, nature of settlement (cash, chips, etc.), and amount of payment. The 

payment slip shall also include the signature of pit supervisory personnel acknowledging 

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payment, and the signature or initials of the dealer or boxperson receiving payment, 

unless this information is included on another document verifying the payment of the 

marker. 

(xvi) Voided markers shall contain the following:

(A) “Void” written across the original marker, issue slip (if available at the time of 

the void) and payment slip.

(B) The reason a marker is voided shall be documented on one part, or other 

document (e.g. log) sufficiently identifying the marker.

(C) Date and time of void on at least one part of the marker.

(D)Signatures on at least one part of the marker (adjacent to the void indication) of 

two pit personnel performing the void, at least one of whom is a pit supervisor. A 

pit clerk may be a nonsupervisory signer. In the event a pit marker is voided later 

by accounting/audit personnel, the signature of two pit personnel authorizing the 

void is required.

(xvii) The voiding process must be completed as follows:

(A) No later than thirty minutes after the issuance of the marker the void must be 

performed, unless the reason for exceeding the time period is documented on one 

part of the marker or other document (e.g. log) sufficient to identify the marker.

(B) All parts of the voided marker shall be transferred to the cage at the end of each 

shift for subsequent transfer to accounting. A voided marker shall not be placed in 

the table game drop box unless the issue slip had been previously dropped. Only 

when markers are voided after the issue slip has been placed in the table game drop 

box shall the dealer insert the voided original marker, or alternate documentation 

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indicating the marker has been voided, into the same table game drop box as the 

issue slip.

Justification: Revisions are intended to establish the minimum controls necessary to 

safeguard the process of voiding of markers. 

(xviii) If a marker payment is made at a table other than the table of issuance and 

the payment (i.e. chips or cash) is transferred to the table of issuance, the following 

standards shall apply:

(A)A transfer document shall accompany the payment to the table of issuance. The 

transfer document shall indicate the date and time, dollar amount of payment, 

marker number, table number where payment was accepted, and table number 

where marker was originally issued. The transfer document shall be signed by the 

dealer accepting the payment from the customer and by the dealer at the table of 

original issuance. The transfer document shall be dropped in the drop box of the 

table where the payment was transferred.

Comment (January): Recommend substituting “to which” for “where” in the 

last sentence. 

Response: Agree. Modified accordingly. 

Proposed revision as a result of January comment: 

(A) A transfer document shall accompany the payment to the table of issuance. The 

transfer document shall indicate the date and time, dollar amount of payment, 

marker number, table number where payment was accepted, and table number 

where marker was originally issued. The transfer document shall be signed by the 

dealer accepting the payment from the customer and by the dealer at the table of 

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original issuance. The transfer document shall be dropped in the drop box of the 

table to which the payment was transferred.

(B) This standard (xviii) is applicable only when marker payments are transferred 

from one table to another open table. A marker payment cannot be made at or 

transferred to a closed table.

(C)The transfer document can be the marker payment slip that provides the 

required information.

(xix) If a marker payment is made by a customer at a table other than the table of 

marker issuance and the payment (i.e. chips or cash) is transferred to the cage, the 

following standards shall apply:

(A)A transfer document shall accompany the payment to the cage. The transfer 

document shall indicate the date and time, dollar amount of the payment, marker 

number, table number where payment was accepted, and cage window where 

payment was transferred. The transfer document shall be signed by the dealer 

accepting the payment and by the cage cashier receiving the marker payment. The 

transfer document shall be forwarded to the accounting department at the end of 

the day.

(B) This standard (xix) is applicable only when the table of marker issuance is 

closed, in which case the marker will be transferred concurrently to the cage in 

accordance with the standards contained herein, or the marker has previously been 

transferred to the cage.

(xx) Once a marker has been transferred from the pit to the cage, any subsequent 

payments shall be transacted and recorded at the cage.

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Justification: Revision is intended to establish the minimum controls specific to the 

receipt of a marker payment other than the table of issuance. In part, the objective of the 

control is to preserve the integrity of the table net win calculation. 

(xvi) (xxi) When partial payments are made in the pit, a new marker shall be completed 

reflecting the remaining balance and the marker number of the marker originally issued. 

(xvii) (xxii) When partial payments are made in the pit, the payment slip of the marker 

that was originally issued shall be properly cross-referenced to the new marker number, 

completed with all information required by paragraph (k)(1)(xv) of this section, and 

inserted into the drop box. (Revised May 4, 2005) 

(xviii) (xxiii) The cashier's cage or another independent source shall be notified when 

payments (full or partial) are made in the pit so that cage records can be updated for such 

transactions. Notification shall be made no later than when the customer's play is 

completed or at shift end, whichever is earlier. This notification may be in the form of 

the pit updating the customer’s credit account in the computer system for the 

payment.

Justification: Revision is intended to identify alternative procedures that may satisfy the 

control. 

(xix) (xxiv) All portions of markers, both issued and unissued, shall be safeguarded and 

procedures shall be employed to control the distribution, use and access to the forms. 

(xx) (xxv) An investigation shall be performed to determine the cause and responsibility 

for loss whenever marker forms, or any part thereof, are missing. These investigations 

shall be documented, maintained for inspection, and provided to the Tribal gaming 

regulatory authority upon request. 

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(xxi) (xxvi) When markers are transferred to the cage, marker transfer forms or 

marker credit slips (or similar documentation) shall be utilized and such documents 

shall include, at a minimum, the date, time, shift, marker number(s), table 

number(s), amount of each marker, the total amount transferred, signature of pit 

supervisory personnel releasing instruments from the pit, and the signature of 

cashier verifying receipt of instruments at the cage. When a mass marker transfer is 

completed at the end of the shift or day to transfer all outstanding markers to the 

cage, the mass marker transfer forms or marker credit slip (or similar 

documentation) shall be utilized. Such documents shall include, at a minimum, the 

document number, date, time, marker number(s), table number(s), amount of each 

marker, the total amount transferred, signature of pit supervisor releasing 

instruments from the pit, and the signature of cashier verifying receipt of 

instruments at the cage. The mass marker transfer form shall be transferred to the 

accounting department on a daily basis.

Comment (January): Mass marker transfers should take place at the end of a 

shift or no later than the end of the day. The current wording fails to 

communicate this and therefore needs revising. 

Response: Agree. Revised accordingly. 

Proposed revision as a result of January comment: 

(xxi) (xxvi) When markers are transferred to the cage, marker transfer forms or 

marker credit slips (or similar documentation) shall be utilized and such documents 

shall include, at a minimum, the date, time, shift, marker number(s), table 

number(s), amount of each marker, the total amount transferred, signature of pit 

supervisory personnel releasing instruments from the pit, and the signature of 

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cashier verifying receipt of instruments at the cage. Mass marker transfers, if 

utilized, shall be performed at the end of the shift or no later than the end of the day 

to transfer all outstanding markers to the cage. Mass marker transfer forms or 

marker credit slip (or similar documentation) shall be utilized. Such documents 

shall include, at a minimum, the document number, date, time, marker number(s), 

table number(s), amount of each marker, the total amount transferred, signature of 

pit supervisor releasing instruments from the pit, and the signature of cashier 

verifying receipt of instruments at the cage. The mass marker transfer form shall 

be transferred to the accounting department on a daily basis.

(xxii) All markers shall be transferred to the cage within twenty-four (24) hours of 

issuance.

(xxiii) (xxvii) Markers shall be transported to the cashier's cage by a person who is 

independent of the marker issuance and payment functions (pit clerks may perform this 

function). 

(2) [Reserved] 

Justification: Revision is intended to recognize and establish the minimum controls 

relevant to a daily transfer of all markers from the pit to the cage. 

(l) (j) Name credit instruments accepted in the pit. 

Comment (January): Will these standards also apply to front money? 

Response: No. 

(1) For the purposes of this paragraph, name credit instruments means personal checks, 

payroll checks, counter checks, hold checks, traveler's checks, or other similar 

instruments that are accepted in the pit as a form of credit issuance to a player with an 

approved credit limit. 

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(2) The following standards shall apply if name credit instruments are accepted in the pit: 

(i) A name credit system shall allow for the issuance of credit without using markers; 

(ii) Unless otherwise known to the employee extending the credit and the personal 

identification information of the player is on file with the gaming operation, verify 

the customer’s identity by examining the customer’s identification credential or 

other reasonable method to ensure the customer’s identity. A customer’s driver’s 

license is the preferred method for verifying the customer’s identity. A passport, 

non-resident alien identification card, other government issued identification 

credential or other picture identification credential normally acceptable as a means 

of identification when cashing checks, may also be used. Subject to approval of the 

Tribal gaming regulatory authority, tribal membership identifications may be

acceptable.

Justification: Proposed revision is intended to establish the requirement that the issuer of 

the named credit instrument must confirm the identity of the customer before executing 

the transaction. 

(ii) (iii) Prior to accepting a name credit instrument, the employee extending the credit 

shall contact the cashier or another independent source to determine if the player's credit 

limit has been properly established and the remaining credit available is sufficient for the 

advance; 

(iii) (iv) All name credit instruments shall be transferred to the cashier's cage (utilizing a 

two-part order for credit) immediately following the acceptance of the instrument and 

issuance of chips (if name credit instruments are transported accompanied by a credit 

slip, an order for credit is not required); 

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(iv) The order for credit (if applicable) and the credit slip shall include the 

customer's name, amount of the credit instrument, the date, time, shift, table 

number, signature of pit supervisory personnel releasing instrument from pit, and 

the signature of the cashier verifying receipt of instrument at the cage;

(v) The procedures for transacting table credits at standards in paragraphs (c)(12) 

through (19) of this section shall be strictly adhered to; and

(vi) The acceptance of payments in the pit for name credit instruments shall be 

prohibited.

Justification: Proposed revision is intended to delete standards that have become 

outdated or determined to be unnecessary. 

(v) Once a check has been transferred from the pit to the cage, any subsequent 

payments shall be transacted and recorded at the cage.

(vi) When traveler’s checks and other guaranteed drafts are accepted at a table 

game, all required issuance and acceptance procedures must be adhered to by the 

drawee and pit personnel. The traveler’s checks and guaranteed drafts shall be 

inserted in the table game drop box by the dealer after chips are issued to the 

customer.

Justification: Proposed revision is intended to establish the minimum controls 

governing the acceptance of traveler’s checks and other guaranteed drafts. 

 Comment (January): Traveler’s checks are not name credit instruments and 

should be a standalone item. 

Response: Agree. Renumbered as (3) 

Proposed revision as a result of January comment: 

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(3) When traveler’s checks and other guaranteed drafts are accepted at a table 

game, all required issuance and acceptance procedures must be adhered to by the 

drawee and pit personnel. The traveler’s checks and guaranteed drafts shall be 

inserted in the table game drop box by the dealer after chips are issued to the 

customer.

(m) (k) Call bets. (1) The following standards shall apply if call bets are accepted in the 

pit: 

(i) A call bet shall be evidenced by the placement of a lammer button, chips, or other 

identifiable designation in an amount equal to that of the wager in a specific location on 

the table; 

(ii) The placement of the lammer button, chips, or other identifiable designation shall be 

performed by supervisory/boxperson personnel. The placement may be performed by a 

dealer only if the supervisor physically observes and gives specific authorization; 

(iii) The call bet shall be settled at the end of each hand of play by the preparation of a 

marker, entry on a rim credit card, repayment of the credit extended, or the payoff of 

the winning wager. Call bets extending beyond one hand of play shall be prohibited; and 

(iv) Lammer buttons shall remain on the table until the call bet is paid with chips or 

cash, or results in the issuance of a marker. For call bets that result in an entry on a 

rim credit card, the lammer button shall remain on the table until the rim credit is 

paid, is transferred to another table or a marker is issued.

Justification: Revision is intended to recognize that a call bet may result in a rim credit 

transaction. 

(iv) The removal of the lammer button, chips, or other identifiable designation shall be 

performed by the dealer/ boxperson upon completion of the call bet transaction. 

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(2) [Reserved] 

Note: Numbering corrected. 

(l) Rim credit. (1) The following standards shall apply if rim credit is extended in the pit: 

(i) Rim credit shall be evidenced by the issuance of chips to be placed in a neutral zone 

on the table and then extended to the customer for the customer to wager, or to the dealer 

to wager for the customer, and by the placement of a lammer button or other identifiable 

designation in an amount equal to that of the chips extended. The lammer buttons shall 

remain on the table until the rim credit is paid or a marker is issued; and 

(ii) Rim credit shall be recorded on player cards, or similarly used documents, which 

shall be: 

(A) Prenumbered or concurrently numbered and accounted for by a department 

independent of the pit; 

(B) Date and time of each balance increase/decrease;

(C) Dollar amount of each balance increase/decrease;

(D) An indication of one or more of the following types of balance increases: 1) 

Issuance of rim credit; 2) Transfer of rim credit balance from another table; or 3) 

Transfer of rim credit balance from the previous shift.

(E) An indication of one or more of the following types of balance decreases: 1) 

Payment in cash; 2) Payment in chips; 3) Issuance of marker; 4) Transfer of rim 

credit to another table; or 5) Transfer of rim credit balance to the next shift.

(B) (F) For all extensions and subsequent repayments, evidenced by the initials or 

signatures of a supervisor and the dealer attesting to the validity of each credit extension 

and repayment; and

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(G) Outstanding rim credit balance.

(C) An indication of the settlement method (e.g., serial number of marker issued, 

chips, cash);

(D) Settled no later than when the customer leaves the table at which the card is 

prepared;

(E) Transferred to the accounting department on a daily basis; and

(F) Reconciled with other forms utilized to control the issuance of pit credit (e.g., 

master credit records, table cards).

(2) For each balance increase/decrease recorded on the customer’s rim card, the 

supervisor and dealer shall compare the actual lammer buttons on the table to the 

outstanding rim credit amount on the customer’s rim card. Any discrepancy 

between the actual lammer buttons evidencing outstanding rim credit on the table 

and the rim credit recorded on the rim card shall be investigated. The results shall 

be documented and retained for a period of time determined by the Tribal gaming 

regulatory authority.

(3) An outstanding rim credit balance shall be reduced to zero by the receipt of 

payment or issuance of a marker no later than when the customer leaves the table, 

unless one of the following occurs:

(A) Rim credit balance is transferred to another table;

(B) The table remains open and fully staffed while the customer is away from the 

table; or

(C) If the table closes, an individual independent of the table games department 

ensures: 1) The rim credit card and lammer buttons are secured at the table until 

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the rim credit balance is paid, marker issued or the customer returns to the table; 2) 

The rim credit is reconciled to the lammer buttons evidencing the outstanding credit 

issuances upon closing and again when the table reopens; and 3) The total balance 

of outstanding rim credit documented on the rim cards is reconciled to the rim 

credit balance carried on the table inventory document at each shift end. 

(4) An outstanding rim credit balance must be reduced to zero through the issuance 

of a marker or payment in full by the customer within seven days from the last date 

of recorded customer rim activity.

(5) Rim cards with a zero balance shall be transferred to the accounting department 

on a daily basis by an individual independent of the rim credit transactions.

Justification: Proposed revisions are intended to clarify and enhance the regulation 

governing rim credit and to establish the controls relevant to the transfer of an 

outstanding rim credit balance to another table. 

(o) (m) Foreign currency. (l) The following standards shall apply if foreign currency is 

accepted in the pit: 

(i) Foreign currency transactions shall be authorized by a pit supervisor/ boxperson who 

completes a foreign currency exchange form before the exchange for chips or tokens; 

(ii) Foreign currency exchange forms include the country of origin, total face value, 

amount of chips/token extended (i.e., conversion amount), signature of supervisor/ 

boxperson, and the dealer completing the transaction; 

(iii) Foreign currency exchange forms and the foreign currency shall be inserted in the 

drop box by the dealer; and 

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(iv) Alternate procedures specific to the use of foreign valued gaming chips shall be 

developed by the Tribal gaming regulatory authority, or the gaming operation as 

approved by the Tribal gaming regulatory authority. 

(2) [Reserved] 

(n) Promotional payouts, drawings and giveaway programs. (1) The conditions for 

participating in promotional payouts, including drawings and giveaway programs, 

shall be prominently displayed or available for customer review at the licensed 

location. 

(i) Applies to promotional payouts, drawings, and giveaway programs in which the 

payouts are made from a bank other than the table inventory, the payouts are 

related to table games wagering activity, and the game play procedures are not 

affected.

(ii) Such payouts are not deductable when reporting assessable gaming revenue. 

Standards do not apply to payouts from the table inventory resulting from a wager 

made with a promotional coupon or chip.

(2) Promotional payouts, including those as a result of drawings and giveaway 

programs, that are greater than or equal to $600 shall be documented at the time of 

the payout to include the following:

(i) Date and time; 

(ii) Dollar amount of payout or description of personal property (e.g., car);

(iii) Reason for payout (e.g., promotion name);

(iv) Signature of one employee verifying, authorizing, and completing the 

promotional payout with the customer; 

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(v) Customer’s name (for drawings only). 

(vi) Documentation may be prepared by an individual who is not a table games 

department employee as long as the required signature is that of the employee 

completing the payout with the customer.

(3) If the promotional cash (or cash equivalent) payout, including those as a result of 

drawings and giveaway programs, is less than $600, documentation is required to be 

created to support the bank accountability for which the payout was made. 

Required documentation consists of a line item on a cage or table games 

accountability document.

Justification: Revision is intended to identify the minimum controls governing table 

game promotional payouts, drawing and giveaway programs that are related to but not 

deductable from table games revenue. Separate payout procedures are specific to 

amounts equal to or greater than $600 and payouts less than $600. 

 Comment (January): Promotional payouts can/are interpreted to be items other 

than cash that are awarded to a player as a result of a winning wager. 

Recommend striking all references to promotional payouts from this standard 

(o). 

Response: Agree. Modified accordingly. 

Comment (January): (A) should read “Applies to drawings, and giveaway 

programs in which the payouts are made from a bank other than the table 

inventory, the payouts are not related to a table games wager, and the game play 

procedures are not affected.” 

Response: Agree. Modified accordingly. 

Comment (January): Recommend adding “or as determined by the IRS 

reporting threshold” after “$600”. 

Response: Agree. Modified accordingly. 

Comment (January): Recommend requiring two employees rather than one to 

verify the payout. 

 Response: Agree. Modified accordingly. 

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Proposed revision as a result of January comments: 

(n) Drawings and giveaway programs. (1) The conditions for participating in 

drawings and giveaway programs, shall be prominently displayed or available for 

customer review at the licensed location. 

(i) Applies to drawings, and giveaway programs in which the payouts are made 

from a bank other than the table inventory, the payouts are not related to table 

games wager, and the game play procedures are not affected.

(ii) Such payouts are not deductable when reporting assessable gaming revenue. 

Standards do not apply to payouts from the table inventory resulting from a wager 

made with a promotional coupon or chip.

(2) Payouts as a result of drawings and giveaway programs that are greater than or 

equal to $600 or as determined by the IRS reporting threshold, shall be documented 

at the time of the payout to include the following: 

(i) Date and time;

(ii) Dollar amount of payout or description of personal property (e.g., car);

(iii) Reason for payout (e.g., promotion name);

(iv) Signature of two employees verifying, authorizing, and completing the payout 

with the customer; 

(v) Customer’s name (for drawings only).

(vi) Documentation may be prepared by an individual who is not a table games 

department employee as long as the required signature is that of the employee 

completing the payout with the customer.

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(3) If the promotional cash (or cash equivalent) payout, including those as a result of 

drawings and giveaway programs, is less than $600 or the IRS reporting threshold, 

documentation shall be created to support the bank accountability for which the 

payout was made. Required documentation consists of a line item on a cage or table 

games accountability document.

Justification: Proposed revision is intended to define the minimum controls relevant to 

table game contests or tournaments. Specifically, the rule stipulates the information that 

must be maintained. 

(o) Contest and tournaments. (1) Entry fees and prize payouts (including mail 

transactions) shall be summarized on a cash accountability document on a daily 

basis.

(2) Entry fee and payout transactions shall be recorded on a document that includes 

the following: 

(i) Customer’s name; 

(ii) Date of entry/payout; 

(iii) Dollar amount of entry fee/payout (both alpha and numeric, or unalterable 

numeric) and/or nature and dollar value of any noncash payout; 

(iv) Signature of individual completing transaction attesting to the receipt or 

disbursement of the entry fee/payout with the customer; and 

(v) Name of contest/tournament.

(3) Contest/tournament entry fees and payouts shall be summarized and posted to 

the accounting records on at least a monthly basis.

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(4) Contest/tournament rules are to be included on all entry forms/brochures or 

prominently displayed and available for customer review upon request. At a 

minimum, the rules must include: 

(i) All conditions customers must meet to qualify for entry into, and advancement 

through, the contest/tournament; 

(ii) Specific information pertaining to any single contest/tournament, including the 

dollar amount of money placed into the prize pool; 

(iii)The distribution of funds based on specific outcomes; 

(iv) Name of the organization(s) that conducted the contest/tournament on behalf 

of, or in conjunction with, the gaming operation, if applicable.

(5) Results of each contest/tournament shall be recorded and available for 

participants to review. The recording shall include the name of the event, date(s) of 

event, total number of entries, dollar amount of entry fees, total prize pool, and the

dollar amount paid for each winning category. The name of each winner shall be 

recorded and maintained but not available to the participants unless approved by 

the Tribal gaming regulatory authority.

Comment (January): The time period for which the documentation must be 

retained is not addressed. 

Response: Agree. Will incorporate the same retention period as required in 

542.13. Modified accordingly. 

Proposed revision as a result of January comment: 

(6) The gaming operation shall establish a reasonable retention period to maintain 

the information, which shall be subject to Tribal gaming regulatory authority 

concurrence. 

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(p) Pool banked table games standards

Comment (March): Concern was expressed that the standards governing pool 

banked table games could be erroneously applied to progressive table games. 

Recommend adding clarifying language. 

Response: Agreed. Modified accordingly. 

Proposed revision as a result of March comment: 

(p) Pool banked table games standards (Does not apply to progressive table games). 

(1) All funds won by the pool from customers shall be returned to the players in 

accordance with the posted rules of the games, which may include:

(i) A combination of pool payout and promotional personal property (e.g., car).

(ii) A combination of pool payout, bonusing awards and progressive pool may be 

offered.

(2) The conditions for participating in current table game pools, bonusing 

programs, progressive pots and any related promotions, including drawings and 

giveaway programs shall be prominently displayed or available for customer review 

at the gaming operation.

(3) Rules governing the conduct of current table game pools shall be conspicuously 

posted and/or available in writing for customer review. The rules, at a minimum, 

shall designate:

(i) The percentage of winnings to be contributed to the table games pool and, if 

applicable, the percentage contributed to any other promotional or progressive pots 

and pools;

(ii) How bonusing awards, promotional payouts and progressive pots and pools will 

be paid out;

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(iii) How/when the contributed funds are added to the pools and pots;

Comment (January): A lengthy discussion was held in which several issues 

were raised including: 

Concern that standard could require posting of proprietary information 

Role of the State in protecting the public’s/player’s interest 

Funds belong to the players and should be returned to them 

Casino has a fiduciary responsibility to the players/public 

Frequently it is not percentages but number of players that are important 

Recommend revising as follows: 

(3) Requirements governing the administration of current table game pools shall be 

conspicuously posted and/or available in writing for customer review. 

Requirements, at a minimum, shall include relevant provisions of the Tribal-State 

compact regarding the administration of table games pools:

(i) The percentage of winnings to be contributed to the table games pool and, if 

applicable, the percentage contributed to any other promotional or progressive pots 

and pools;

(ii) How bonusing awards, promotional payouts and progressive pots and pools will 

be paid out;

(iii) How/when the contributed funds are added to the pools and pots;

Response: Agreed. Modified accordingly. 

(3) Requirements governing the administration of current table game pools shall be 

conspicuously posted and/or available in writing for customer review. 

Requirements, at a minimum, shall include relevant provisions of the Tribal-State 

compact regarding the administration of table games pools:

(i) The percentage of winnings to be contributed to the table games pool and, if 

applicable, the percentage contributed to any other promotional or progressive pots 

and pools;

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(ii) How bonusing awards, promotional payouts and progressive pots and pools will 

be paid out;

(iii) How/when the contributed funds are added to the pools and pots;

(4) Pool contributions shall not be placed in or near the rake circle.

Comment (January): “Rake” is a poker term, not used in pool-banked table 

games. Ante is the appropriate term. Recommend revising. 

Response: Agree. Modified accordingly. 

Proposed revision as a result of January comment: 

(4) The ante shall not be commingled with the pool funds.

(5) The amount (balance) of the pools and pots shall be conspicuously displayed in 

the table games area.

(6) At least once a day, the posted balance of the pools and pots shall be updated to 

reflect their current amount.

(7) At least once a day, increases and decreases to the posted balance of the pools 

and pots shall be reconciled to the amount received by the cage from the count team 

by personnel independent of table games. 

Justification: Pool table game standards are proposed to ensure gaming operations are 

effective in accounting for the pool balance and any other promotional progressives or 

pots to which winnings may be contributed. Additionally, the controls strive to ensure 

there is minimum disclosure to the public regarding the administration of the pools and 

pots. 

Comment (January): A lengthy discussion was held in which the following points 

were made by the Committee: 

- The amount of the pool has no effect on the amount that a player can win on a 

particular game as that is determined by the table limit. 

- Posting the amount of the below may mislead players into believing that they 

can win that amount. 

- It would be difficult to determine the balance of the pool on a daily basis as 

there are often outstanding expenses to be deducted therefrom. 

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Response: Agree to delete the requirement that the balance be posted. Modified 

accordingly. 

(5) The amount (balance) of the pools and pots shall be conspicuously displayed in 

the table games area.

(6) At least once a day, the posted balance of the pools and pots shall be updated to 

reflect their current amount.

(7) At least once a day, increases and decreases to the posted balance of the pools 

and pots shall be reconciled to the amount received by the cage from the count team 

by personnel independent of table games. 

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