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iN Gaauin Office

June 28, 2017

Via Email (vannice_doulou@nige.gov) & U.S. Mail

/Mr, Jonedev Chaudhuri, Chairman
National Indian Gaming Commission
ATTN: Vannice Doulou

C/O Department of the Interior

1849 C Street NW

Mail Stop #1621

Washington, DC 20240

Dear Chairman Chaudhuri:
On behalf of the Jackson Band of Miwuk Indians I am submitting the following comments.

The Jackson Band of Miwuk Indians conducts Class I gaming at the Jackson Rancheria Casino
Resort in Jackson, California. We appreciate the National Indian Gaming Commission’s opportunity
to provide comment on the NIGC’s proposal to issue guidance that tribal regulators may use in

/, developing their own Class II] internal controls, and also to maintain in the federal register the Class
III Minimum Internal Control Standards at 25 CFR Part 542 in a suspension status.

‘We support the NIGC’s continued provision of minimum internal control standards for Class III
gaming, specifically: (1) The NIGC’s current decision to maintain the Class III MICS at 25
CFR Part 542, in a suspension status that ensures the text adopted in 2006 will remain on the
books and also specifies that it is not enforceable without the Tribe’s express consent; and (2)
The NIGC’s current decision to provide guidance on updates or best practice recommendations
for the Class III MICS. We further urge the NIGC to specify that such guidance on updated
Class III MICS “meet or exceed” the 2006 MICS at 25 CFR Part 542, for the reasons
specified below.

The federal regulatory standards for Class III] Gaming MICS at 25 CFR Part 542 have an
important and positive impact on the industry, serving since 1999 as a uniform and solid
baseline for tribes to issue their own tribal internal control standards. The uniform federal
ininimum standard facilitates regulatory compliance in such areas as external audit and shortens
the learning curve for internal audit, facility audit and regulators recruited from another state or
tribal jurisdiction. The industry’s reliance upon the federal standard has roots in the historical
evolution of Indian gaming as well as their efficiency and effectiveness.

Our Tribe has adopted the federal MICS standard. The federal Class III MICS currently are used
as the standard in tribal-state gaming compacts, regulations, tribal gaming ordinances, and
Secretarial procedures. In California, in addition to new compacts and compact amendments
incorporating the federal Class III MICS, a state-wide regulation called CGCC-8 enacted
pursuant to the compact incorporates the federal MICS standards.

Executive Office
Director: 209-223-8250 _ Fax 209- 223- 8388
‘Administrative Assistant: 209-223-6253 Fax 209- 223- 8388

P.O. Box 1090, Jackson, CA 95642 - 800-822-WINN (9466) - JacksonCasino.com



(JACKSON

We agree that the federal Class III MICS standard should remain in place, and any review of these
standards and regulations at this stage should carefully take into account the important role these
‘standards have played and continue to play for many tribes.

Most importantly, we urge the NIGC to specify in its guidance that such guidance updates
/, “meet or exceed” the Class III MICS published at 25 CFR Part 542. This will avoid any
unnecessary confusion and also compliment the approach taken in many compacts, regulations,
_ ordinances, and Secretarial Procedures. This enables tribes the option to choose to adopt the updates
into their tribal MICS, preserving some of the federal uniformity of regulation in the industry and
avoiding costly duplication of efforts. _This approach also compliments the California state-wide
regulation CGCC-8, which provides for the standard of compliance to be 25 CFR Part 542 as in effect
on October 19, 2006, or as it may be amended, as well as an alternative material compliance standard
where a tribe adopts MICS that meet or exceed 25 CFR Part 542, as in effect on October 19, 2006, or
as it may be amended. This approach also compliments new compacts in California which refer to and
require implementation of standards that are no less stringent than those contained in the NIGC MICS
published in 2006, and as they may thereafter be amended.

With respect to comments on the specific proposed guidelines, we request that the NIGC consider the
following revision to the proposed guidance for controlled keys at Section 15(c): Combining (v) and

/ (iii) so that the storage component/Kiosk release are referred to together, and combining (vi) with (iv)
so that drop box/storage component/Kiosk content are referred to together, both where Surveillance is
notified prior to and during access. We think that having only one type of Stacker release key
(regardless if for the Kiosk or Machine) combined with Surveillance notification and coverage
enhances security since it is easier to track and maintain.

We appreciate this opportunity to provide written comment and look forward to any continued
consultation on these issues.

Sincerely, P.
Kelly Steinhoff

Executive Director

CC: Adam Dalton, Tribal Chairperson
Rich Hoffman, Chief Executive Officer
Jane Zerbi, Esq.

@ Page 2 June 28, 2017

P.O. Box 1090, Jackson, CA 95642 : 800-822-WINN (9466) : JacksonCasino.com