§ 542.9 What are the minimum internal control standards for card 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 card game 

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

applicable). 

(c) Standards for supervision. (1) Supervision shall be provided at all times the card room 

is in operation by personnel with authority equal to or greater than those being 

supervised. 

Comment (December): “Card room” is not defined. 

Response: Agree. Definition has been added to 542.2 as follows: 

Card room means a room set aside for the conduct of card games, such as 

poker. In such games the customers wager against each other rather than 

against the gaming operation’s bankroll. The revenue derived by the gaming 

operation is merely a percentage rake-off or a time buy-in (commission 

charged to play).

Comment (January): Card games are sometimes conducted in areas that have 

mixed game types, such as card games and table games. 

Response: Agree. The definition is not intended to preclude a table game 

from being located in general proximity to a card game. 

Comment (January): The first sentence sufficiently defines the term, remove the 

last two sentences. 

Response: Agree. Definition revised accordingly. 

Comment (January): Replace “room” with “area”. 

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Response: Agree. Definition is revised as follows: 

Card room means an area set aside for the conduct of card games, such as poker.

(i) Provided the card game is recorded by the surveillance department:

(A.) A supervisor may function as a dealer without any other supervision for a 

period of time of less than one hour if disputes are resolved by supervisory 

personnel independent of the card games department; or 

(B.) A dealer may function as a supervisor, if not dealing the game.

Justification: Permitting a supervisor to function as a dealer and a dealer to function as a 

supervisor under limited circumstances provides the gaming operation with flexibility in 

staffing. 

Comment (December): Remove the provision (i), redundant to 542.43(k). 

Response: Agree. Surveillance condition is redundant with proposed revision to 

542.43(l), which would also be applicable to the corresponding control in 542.23 

and 542.33. After striking (c)(1)(i), (c)(1)(i)(A) becomes (c)(1)(i), and 

(c)(1)(i)(B) becomes (c)(1)(ii). 

Comment (December): Replace “Provided” with “If”. 

Response: Considering above revision, comment is no longer applicable. 

Revised proposal as a result of December comments: 

(i) A supervisor may function as a dealer without any other supervision for a period 

of time of less than one hour if disputes are resolved by supervisory personnel 

independent of the card games department; or 

(ii) A dealer may function as a supervisor, if not dealing the game.

Comment (January): Remove (c) (1) (i) and (c) (1) (ii), or include TGRA 

approval requirement for both. 

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Response: Disagree. The standard is intended to recognize and accept that there 

may be times when a supervisor will need to function as a dealer and times when 

a dealer will be required to function in a supervisory capacity. The TGRA 

already has the authority to impose standards more stringent that those contained 

in the MICS, refer Section 542.3(c). 

Comment (January): Apply (c) (1) (i) and (c) (1) (ii) to Tier A only, or to Tier A 

and Tier B only. 

Response: Disagree. Although the additional latitude afforded is likely to be 

relevant to smaller poker rooms, the need for such an alternative is not limited to 

just Tier A and B properties. 

Comment (January): Replace (c) (1) (i) and (c) (1) (ii) with a general standard 

for TGRA determination of alternative supervision procedures. 

Response: Disagree. Although the proposed standard is granting greater latitude 

to management, it also imposes conditions. If the supervisor is functioning as a 

dealer, disputes must be resolved by a supervisor independent of the card game 

department and, if a dealer is functioning as a supervisor, the dealer is prohibited 

from dealing a game. Although the TGRA has the latitude of disallowing the 

options provided by the proposed regulation or attaching more stringent 

standards, the need for the minimum conditions to exist justifies the codification 

of the rule. 

Comment (January): In the preceding suggested replacement general standard, 

include a provision that the dealer will not resolve disputes arising from the game 

he/she is dealing. 

Response: Agree. Proposed regulation is revised as follows. 

Revised proposal as a result of January comments: 

(i) A supervisor may function as a dealer without any other supervision if disputes 

are resolved by supervisory personnel independent of the card games department; 

or 

(ii) A dealer may function as a supervisor, if not dealing the game.

(2) Exchanges between table banks and the main card room bank (or cage, if a main card 

room bank is not used) in excess of $100.00 shall be authorized by a supervisor. All 

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exchanges shall be evidenced by the use of a lammer unless the exchange of chips, 

tokens, and/or cash takes place at the table. If table banks are maintained at an 

imprest level and runners are used for the exchanges at the table, no supervisory 

authorization is required.

Justification: The $100 threshold was eliminated due to its inconsistency with accepted 

gaming industry practice and its minimal applicability. The addition is intended to 

facilitate exchanges when the table is maintained on an imprest basis. 

(3) Exchanges from the main card room bank or cage, (if a main card room bank is not 

used) to the table banks shall be verified by the card room dealer and the runner. 

(4) If applicable, transfers between the main card room bank and the cage shall be 

properly authorized and documented. Documentation must be retained for 24 hours.

Justification: Establishing a minimum time period for retention of documentation is 

intended to facilitate subsequent reconciliation and investigation of variances. 

Comment (December): Retention requirement should be “at least 24 hours”. 

 Response: Agree. Revised accordingly. 

Revised proposal as a result of December comment: 

(4) If applicable, transfers between the main card room bank and the cage shall be 

properly authorized and documented. Documentation must be retained for at least 24 

hours.

(5) A rake collected or ante placed shall be done in accordance with the posted rules. 

(d) Standards for playing cards. (1) Playing cards shall be maintained in a secure 

location to prevent unauthorized access and to reduce the possibility of tampering.

(2) Used cards shall be maintained in a secure location until marked, scored, or 

destroyed, in a manner approved by the Tribal gaming regulatory authority, to 

prevent unauthorized access and reduce the possibility of tampering.

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(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 from play.

(1) New and used playing cards to be issued to a table shall be maintained in a 

secure location to prevent unauthorized access and reduce the possibility of 

tampering. Used playing cards that are not to be re-used shall be properly canceled 

and removed from service.

Comment (December): Add “subject to procedures established by the gaming 

operation subject to TGRA approval” to the end of the last sentence. 

Response: Agree Revised accordingly.

Revised proposal as a result of December comment: 

(1) New and used playing cards to be issued to a table shall be maintained in a 

secure location to prevent unauthorized access and reduce the possibility of 

tampering. Used playing cards that are not to be re-used shall be properly canceled 

and removed from service. The cancelation and removal procedure shall be subject 

to TGRA review and approval.

(i)(2) This standard shall not apply where playing cards are retained for an investigation. 

(ii) [Reserved]

Justification: Revision is intended to result in a more concise and clearer standard. 

(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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(e) Plastic cards. Notwithstanding paragraph (d) 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: Deletion is intended to provide greater latitude to management in 

determining the useful life of cards in play. 

(e)(f) Standards for shills. (1) Issuance of shill funds shall be recorded on a shill signout form and shall have the written approval of the supervisor. 

(2) Shill returns shall be recorded and verified on the shill sign-out form. Returned 

shill funds shall be recorded on a shill sign-out form and verified by a supervisor 

who signs the form.

Justification: Revisions are intended to clarify the standard and to ensure that an audit 

trail supporting the issuance and return of shill funds is created. 

(3) The replenishment of shill funds shall be documented. 

(f)(g) Standards for reconciliation of card room bank. (1) The amount of the main card 

room bank shall be counted, recorded, and reconciled on at least a per shift basis. at 

least once every eight hours. 

Comment (December): Add “or when accountability transfers” to the end of the 

last sentence. 

Response: Agree 

Revised proposal as a result of December comment: 

(f) (g) Standards for reconciliation of card room bank. (1) The amount of the main card 

room bank shall be counted, recorded, and reconciled on at least a per shift basis. at 

least once every eight hours or when accountability transfers. 

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Justification: Revisions are intended to clarify the standard and to ensure that an audit 

trail supporting the issuance and return of shill funds is created. 

(2) At least once per shift every eight hours, the table banks that were opened during 

that shift shall be counted, recorded, and reconciled by a dealer or other person, and a 

supervisor (or an employee independent of the card games department), and shall be 

attested to by their signatures on the check-out form. For imprest banks that remain 

with the dealer, the banks shall be counted, recorded and reconciled upon issuance 

and upon return by the dealer and a supervisor (or an employee independent of the 

card games department), and attested to by their signing the checkout form. 

Justification: The revision is intended to ensure that the table banks are counted, 

recorded, and reconciled at least once every eight hours. Additionally, an alternative to a 

supervisor performing the count and reconciliation is afforded the gaming operation. The 

alternative allows for the task to be performed by an employee independent of the card 

games department. Furthermore, standards are proposed to address the procedure in 

which imprest table banks are issued to and returned by a dealer. 

(g) (h) Standards for promotional progressive pots and pools. (1) All funds contributed 

by players into the pools shall be returned when won in accordance with the posted rules 

with no commission or administrative fee withheld. 

(i) The payout may be in the form of personal property (e.g., car).

(ii) A combination of a promotion and progressive pool may be offered.

Justification: The revision is intended to clarify that the payout may be in the form of 

personal property and that a promotion may be an element of the payout. 

(2) The conditions for participating in card game promotional progressive pots, 

pools, and any related promotions including drawings and giveaway programs shall 

be prominently displayed or available for customer review at the gaming operation.

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Comment (December): The NIGC is without jurisdiction to regulate any 

promotion that occurs within a gaming facility. This is the responsibility of the 

TGRA, and therefore the proposed standard should be revised to reflect that the 

gaming operation, subject to TGRA approval, shall develop and implement 

policies and procedures to ensure that the card room customers are aware of the 

card game promotional rules and eligibility requirements. 

Response: Disagree. Standards governing card room promotional pots and pools 

have been in the NIGC MICS since their first publication in January 1999. The 

promotional activities are directly related to the conduct of the gambling games 

and the codification of minimum internal control standards applicable to the 

conduct and accounting for the activity and transactions has been determined by 

the Commission to be within the scope of its authority. 

Comment (December): Limit standard to current events. 

Response: Agree. 

Revised proposal as a result of December comments: 

(2) The conditions for participating in current card game promotional progressive 

pots, pools, and any related promotions including drawings and giveaway programs 

shall be prominently displayed or available for customer review at the gaming 

operation.

Justification: The MICS is currently silent with regard to requiring the posting of the 

conditions for participation in a pot, pool or related promotion. The proposed revision is 

intended to codify the requirement that the conditions for participation be made available 

to the card room customers. 

(3) Payouts for card game promotional progressive pots, pools and any other 

promotion, including related drawings and giveaway programs, that are $500 or 

more 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);

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(iv) Signature of one employee verifying, authorizing, and completing the 

promotional payout with the customer. The employee need not be a card game 

department employee provided that the required signature is that of the employee 

completing the payout with the customer; and

(v) Customer’s name.

Justification: The MICS is currently silent regarding payout documentation. The 

revision is intended to identify the accepted controls specific to the payout procedure, 

customer identification, and proper authorization and verification. It is noteworthy that 

the controls requested are relevant to payouts of $500 or more. 

Comment (December): Change $500 threshold to $600, the IRS reporting 

threshold. 

Response: Agree. 

Revised proposal as a result of December comment: 

(3) Payouts for card game promotional progressive pots, pools and any other 

promotion, including related drawings and giveaway programs, that are $600 or 

more 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. The employee need not be a card game 

department employee provided that the required signature is that of the employee 

completing the payout with the customer; and

(v) Customer’s name.

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(4) If the cash (or cash equivalent) payout for the card game promotional 

progressive pot, pool, or related promotion, including a payout resulting from a 

drawing or giveaway program, is less than $500, documentation shall be created to 

support accountability of the bank from which the payout was made. Such 

documentation may consist of a line item on a card games department or cage 

accountability document (e.g., 43 (forty-three) $10 card games giveaway coupons = 

$430).

Justification: The MICS is currently silent regarding payout documentation. The 

revision is intended to identify the minimum documentation needed to support the bank 

accountability for payouts of less than $500. It is noteworthy that the standard establishes 

less stringent documentation requirements for payouts of less than $500. 

Note: To ensure congruity with above subsection (3), the follow amended proposed 

revision to (4) is as follows: 

Revised proposal incorporating note: 

(4) If the cash (or cash equivalent) payout for the card game promotional 

progressive pot, pool, or related promotion, including a payout resulting from a 

drawing or giveaway program, is less than $600, documentation shall be created to 

support accountability of the bank from which the payout was made. Such 

documentation may consist of a line item on a card games department or cage 

accountability document (e.g., 43 (forty-three) $10 card games giveaway coupons = 

$430).

(5)(2) Rules governing promotional pools shall be conspicuously posted in the card 

room and/or available in writing for customer review. The rules shall and designate: 

Comment (December): Limit standard to current events. 

Response: Agree 

Revised proposal as a result of December comment: 

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(5)(2) Rules governing current promotional pools shall be conspicuously posted in 

the card room and/or available in writing for customer review. The rules shall and

designate: 

(i) The amount of funds to be contributed from each pot; 

(ii) What type of hand it takes to win the pool (e.g., what constitutes a “bad beat”); 

(iii) How the promotional funds will be paid out; 

(iv) How/when the contributed funds are added to the jackpots pools; and 

(v) Amount/percentage of funds allocated to primary and secondary jackpots pools, if 

applicable. 

Justification: The proposed revisions clarify that the rules need not be posted but may 

be made available in writing to customers. Additional changes were made to correct 

terminology. 

(6) (3) Promotional pool contributions shall not be placed in or near the rake circle, in the 

drop box, or commingled with gaming revenue from card games or any other gambling 

game.

(7)(4) The amount of the jackpots pools shall be conspicuously displayed in the card 

room. 

Justification: Correction of terminology. 

(8)(5) At least once a day, the posted pool amount shall be updated to reflect the current 

pool amount. 

(9)(6) At least once a day, increases to the posted pool amount shall be reconciled to the 

cash previously counted or received by the cage by personnel independent of the card 

room. 

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(10)(7) All decreases to the pool must be properly documented, including a reason for the 

decrease. 

(i) Promotional progressive pots and pools where funds are displayed in the card room. 

(1) Promotional funds displayed in the card room shall be placed in a locked 

container in plain view of the public.

(2) Persons authorized to transport the locked container shall be precluded from 

having access to the contents keys.

(3) The contents key shall be maintained by personnel independent of the card 

room.

(4) At least once a day, the locked container shall be removed by two persons, one of 

whom is independent of the card games department, and transported directly to the 

cage or other secure room to be counted, recorded, and verified.

(5) The locked container shall then be returned to the card room where the posted 

pool amount shall be updated to reflect the current pool amount.

Justification: It is proposed that the standards be struck because the noted procedures 

(related to funds displayed in the card room) have minimal applicability to tribal gaming. 

(j) Promotional progressive pots and pools where funds are maintained in the cage. 

(11)(1) Promotional funds removed from the card game shall be placed in a locked 

container (e.g., a separate locked container affixed to a card game table used solely 

for promotional pool funds).

Justification: Revision is intended to clarify the reference to locked container. 

(12) (2) Persons authorized to transport the locked container shall be precluded from 

having access to the contents keys. 

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(13) (3) The contents key shall be maintained by personnel a department independent 

of the card room. 

Justification: The revision is intended to clarify that the key shall be maintained by a 

department rather than an individual. 

(14) (4) At least once a day, the locked container shall be removed by two persons, one of 

whom is independent of the card games department, and transported directly to the cage 

or other secure room to be counted, recorded, and verified, prior to accepting the funds 

into cage accountability. 

(5) The posted pool amount shall then be updated to reflect the current pool 

amount.

Justification: The standard is proposed to be struck because of its redundancy with 

542.9 (h) (8). 

(h) Card Room Contests and Tournaments (1) All contest/tournament entry fees and 

prize payouts (including mail transactions) shall be summarized on a cash 

accountability document on a daily basis.

Comment (December): The parenthetical “including mail transactions” could 

raise other questions about what is exempted from the term “all”. Recommend 

striking the parenthetical.

Response: Agree 

Revised proposal as a result of December comment: 

(1) All contest/tournament entry fees and prize payouts shall be summarized on a 

cash accountability document on a daily basis.

(2) When contest/tournament entry fees and payouts are transacted, the 

transactions shall be recorded on a document which contains:

(i) Customer’s name;

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(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.

Comment (December): The proposed standard is burdensome for gaming 

facilities, therefore we recommend that the standard should be applicable to only 

those buy-ins/payouts as required by the IRS/Department of Treasury. 

Additionally, the NIGC needs to take into account how this requirement may 

invalidate any compact provisions that must be complied with by a tribe. This 

new requirement will slow down the play of cards in the gaming facilities and 

affect the amount of revenue that is transferred to the state because customers and 

employees are needlessly tied up with paperwork on insignificant dollar amounts. 

Response: Disagree that the proposed revision could affect a tribe’s compliance 

with a Tribe/State Compact. At Section 542.4 of the MICS, it is stated that, in the 

event of a conflict between the MICS and a Compact, the Compact shall prevail. 

Disagree that the proposed revision will unnecessarily have an unfavorable impact 

on the card room operation. The standards do no more than codify the need to 

document entry fees received in which the identity of the patron is needed to 

make the payout and payouts of $600 or more. The proposed controls are 

essential to ensuring such transactions are appropriately authorized and recorded. 

Comment (December): Separate requirements related to entry fees, and those 

related to payouts. 

Response: Agree. Amended proposed revision follows that address buy-ins 

separately than payouts. 

Revised proposal as a result of December comments: 

(2) When contest/tournament entry fees and the identification of the entrant is 

necessary to making the payout, the transactions shall be recorded on a document 

which contains:

(i) Customer’s name;

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(ii) Date of entry;

(iii) Dollar amount of entry fee (both alpha and numeric, or unalterable numeric);

(iv) Signature of individual completing transaction attesting to the receipt the entry 

fee with the customer; and

(v) Name of contest/tournament.

Comment (January): Response and revised proposal do not adequately address 

concerns about recording each entrant’s name. 

Response: Agree. Proposed regulation will be revised to add clarity. 

Comment (January): Entrant identification should occur at the conclusion of the 

tournament. 

Response: Disagree. The standard is applicable to events in which the 

collection of entrant’s identifying information is necessary to the conduct of the 

event. 

Comment (January): A customer might be reluctant to enter a tournament if 

required to provide his/her name. 

Response: Disagree. The standard is applicable to events in which the 

collection of entrant’s identifying information is necessary to the conduct of the 

event. 

Comment (January): Include a clarifying parenthetical “(i.e., high hand of the 

day)”. 

Response: Agree. Proposed regulation will be revised accordingly. 

Comment (January): Tournament entry fee standards should be determined by 

the gaming operation, and excluded from the NIGC MICS. 

Response: Disagree. The proposed regulation is not intended to inhibit 

management creativity in the conduct of tournaments or other similar activities 

but possesses the objective of ensuring the participants are adequately informed of 

the rules governing the activity and that the event is appropriately recognized and 

recorded in the books and records of the gaming operation. 

Comment (January): Committee recommended revision: 

(2) When, in accordance with the rules of the contest/tournament as established 

by the gaming operation, identification of the entrant is required for making the 

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subsequent payout of $600 or more,(e.g., high hand of the day/week), the entry 

fee(s) shall be recorded on a document which contains: 

(i) Customer’s name; 

(ii) Date of entry; 

(iii) Dollar amount of entry fee (both alpha and numeric, or unalterable numeric); 

(iv) Signature of individual completing transaction attesting to the receipt the 

entry fee with the customer; and 

(v) Name of contest/tournament. 

Response: Agree. The above proposed revision is accepted. Proposed 

revision is amended as follows. 

Revised proposal as a result of January comments: 

(2) When, in accordance with the rules of the contest/tournament as established by 

the gaming operation, identification of the entrant is required for making the 

subsequent payout of $600 or more,(e.g., high hand of the day/week), the entry fee(s) 

shall be recorded on a document which contains:

(i) Customer’s name;

(ii) Date of entry;

(iii) Dollar amount of entry fee (both alpha and numeric, or unalterable numeric);

(iv) Signature of individual completing transaction attesting to the receipt the entry 

fee with the customer; and

(v) Name of contest/tournament.

(3) When contest/tournament payouts of $600 or more are transacted, the 

transactions shall be recorded on a document which contains:

(i) Customer’s name;

(ii) Date of payout;

(iii) Dollar amount of entry payout (both alpha and numeric, or unalterable 

numeric) and/or nature and dollar value of any noncash payout;

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(iv) Signature of individual completing transaction attesting to the disbursement of 

the payout with the customer; and

(v) Name of contest/tournament.

(4) Contest/tournament prize pools that have the amount of the pool determined 

through player contributions from card game pots are subject to the requirements 

of §542.9 (g) (5) and §542.9 (g) (11)-(14). 

(5) The contest/tournament entry fees and payouts shall be summarized and posted 

to the accounting records on at least a monthly basis.

(6) Contest/tournament rules shall be included on all entry forms/brochures and 

prominently displayed or available for customer review at the gaming operation. 

The rules must include at a minimum:

Comment (December): Limit standard to current events. 

Response: Agree

Revised proposal as a result of December comment: 

(6) Current contest/tournament rules shall be included on all entry forms/brochures 

and prominently displayed or available for customer review at the gaming 

operation. The rules must include at a minimum:

Comment (December): Modify to remove potential inference that entry forms and/or 

brochures must be produced. 

Response: Disagree. The rules must be included on the entry forms or brochures and 

prominently displayed; or, in the alternative, the rules must be provided by the gaming 

operation to customers. If management opts for the alternative, the rules must be 

produced upon request from a customer. 

(i) All conditions customers must meet to qualify for entry into, and 

advancement through, the contest/tournament;

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(ii) Specific information pertaining to any single contest/tournament, including the 

dollar amount of money placed into the prize pool; and

Comment (December): Replace “dollar amount of money placed into the prize 

pool” with “types and amounts of prizes”. 

Comment (December): The dollar amount is not always determinable 

beforehand. Strike the phrase following the comma. 

Response: Agree. 

Revised proposal as a result of December comments: 

(ii) Specific information pertaining to any single contest/tournament, inclusive of the 

following:

(A) Dollar amount of money placed in to the prize pool;

(B) If dollar amount not predetermined, the method by which the dollar 

contribution will be determined; and

(C) Description of merchandise contributed, inclusive a dollar value. 

(iii)The distribution of funds based on specific outcomes.

Comment (December): Change “specific outcomes” to “expected outcomes”. 

Response: Disagree. With regard to contests and tournaments, the reference to 

specific outcomes is the more applicable term. 

(7) Results of each contest/tournament shall be recorded and available for 

participants to review, including 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. 

Comment (December): Limit standard to current events, and limit the 

availability for review to the conclusion of the event, or within a reasonable time 

thereafter as determined by the TGRA. 

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Response: Agree with comment pertaining to current events and a reasonable 

period to request information on a closed event. 

Comment (December): Results available for review should include the name of 

the winner only at the winner’s discretion. 

Response: Disagree that the standard should reference the identity of the winner. 

The TGRA has the latitude of making the control more stringent. 

Comment (December): Replace “available” with “posted”. 

Response: Disagree with requiring the information to be posted. Obligating 

management to provide the information upon request within a reasonable period 

is a sufficient control. 

Comment (December): Strike “participants to”. 

Response: Disagree that the reference to participants should be struck. 

Customers of the gaming operation that participated in a contest or tournament 

have a vested interest in the noted information. 

Comment (December): Limit availability for review to dispute resolution only. 

Response: Disagree that the dissemination of the information should be limited 

to customers that dispute the outcome. Participants should have the latitude of 

requesting the information on the outcome of the event. 

Comment (December): Replace “participants” with “TGRA”. 

Response: Disagree that access to the information should be limited to the 

TGRA, which already has the authority to review the data. The control is 

intended to ensure participants in the contest or tournament have the right to 

review the information. 

Revised proposal as a result of December comments: 

(7) Results of current contests/tournaments shall be recorded and available for 

participants to review, including 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 gaming operation shall establish a 

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reasonable retention period to maintain the information, which shall be subject to 

TGRA concurrence. 

(i) For free tournaments (i.e., customer does not pay an entry fee), the 

above information must be recorded except for the number of entries, 

dollar amount of entry fees and total prize pool.

Comment (December): This is not a wagering activity and the prize may not be 

coming out of the prize pool but rather the marketing department. Free 

tournaments are not gaming activities and the NIGC is without authority to 

regulate these types of activities. These are management issues that should be 

regulated by the TGRA. 

Response: Agree, (h)(7)(i) struck. Note: (h)(7)(ii - iv) then become (h)(7)(i - iii). 

Revised proposal as a result of December comment: 

(i) For free tournaments (i.e., customer does not pay an entry fee), the 

above information must be recorded except for the number of entries, 

dollar amount of entry fees and total prize pool.

(i) (ii) For contest/tournament prize pools where the amount of the pool is

determined through customer contributions from card game pots, the daily 

contributions and the total contributions shall be recorded.

(ii) (iii) Two employees, one of whom is independent of the collection of entry fees, 

shall reconcile the total amount of card game chips issued for the 

contest/tournament in exchange for entry fees to the final chip count at the end of 

the contest/tournament. The reconciliation shall be documented and signed by the 

employees. 

(iii) (iv)The aforementioned contest/tournament records shall be maintained for 

each event.

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Comment (December): Strike, duplicates (h)(6) 

Response: Agree. (h)(6)(iii) struck. 

Revised proposal as a result of December comment: 

(iii) (iv) The aforementioned contest/tournament records shall be maintained for 

each event.

(i) Computerized Player Tracking Systems

Comment (December): Recommend that the NIGC review 542.13(j) at the same 

time this subsection is reviewed by the Committee in order to ensure that the 

proposed language is consistent with current standards because nearly every 

gaming facility has the same player tracking systems for both gaming machines 

and card games. 

Response: Agree/Disagree. The current gaming machine section pertaining to 

player tracking systems is anticipated to be revised to coincide with the standards 

herein. 

Comment (January): Player tracking system standards should be in a separate 

section that encompasses all game types. 

Response: Disagree. The player tracking system controls are specific to the 

individual gaming revenue centers. 

(1)The following standards apply only to computerized player tracking systems that 

accumulate points that are subsequently redeemed by the customer for cash, 

merchandise, etc. 

(2)The addition/deletion of points to player tracking accounts other than through an 

automated process related to actual play must be sufficiently documented (including 

substantiation of reasons for increases) and authorized/performed by supervisory 

personnel of the player tracking, promotions, or card games departments. 

Comment (December): Remove the term “supervisory” and state that the 

personnel must be authorized by the TGRA to perform this function. 

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Response: Disagree. The standard recognizes the importance that the 

transactions be performed or authorized by a supervisor. If the TGRA were to 

determine that its approval of the individuals possessing the authority to make 

point adjustments is warranted, it has the authority to establish a more stringent 

control. 

Comment (December): Replace “authorized/performed" with “authorized or 

performed”. 

 

Response: Agree. Revised accordingly. 

 

Revised proposal as a result of December comment: 

(2)The addition/deletion of points to player tracking accounts other than through an 

automated process related to actual play must be sufficiently documented (including 

substantiation of reasons for increases) and authorized or performed by supervisory 

personnel of the player tracking, promotions, or card games departments. 

Comment (December): Add “or authorized designee” after “supervisory 

personnel” here and throughout subsection (i). 

Response: Disagree. The previous revision is sufficient to communicate that the 

authorization of the adjusting entry by a supervisor is acceptable. 

(i) The addition/deletion of points to player tracking accounts authorized by 

supervisory personnel shall be documented and randomly verified by 

accounting/audit personnel on a quarterly basis.

Comment (December): The random verification should be more frequent than 

quarterly. 

Comment (December): Strike “on a quarterly basis”. 

Comment (December): Replace “on a quarterly basis” with “on at least a 

quarterly basis, or more often as determined by the TGRA”. 

Response: Agree. Revised accordingly. 

Revised proposal as a result of December comments: 

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(i) The addition/deletion of points to player tracking accounts authorized by 

supervisory personnel shall be documented and randomly verified by 

accounting/audit personnel on at least a quarterly basis.

(ii)The above requirements do not apply to the deletion of points related to inactive 

or closed accounts through an automated process.

(3) Employees who redeem points for patrons shall not have access to inactive or 

closed accounts without supervisory personnel authorization. Documentation of 

such access and approval shall be created and maintained. 

(4) Customer identification is required when redeeming points without a player 

tracking card.

Comment (December): ID should always be required when redeeming points. 

Strike “without a player tracking card”.

Response: Agree/Disagree that sufficient risk is posed to justify the requirement 

that all cases in which points are being redeemed should require the patron to 

present their ID, e.g. nominal purchases such as a buffet. However, when gaming 

operations allow patrons to redeem points for cash, the risk is sufficiently elevated 

to require the additional control. 

Revised proposal as a result of December comment: 

(4) Customer identification shall be required when redeeming points for cash or at 

any time points are being redeemed without a player tracking card.

(5) Changes to the player tracking system parameters, such as point structures and 

employee access, must be performed by supervisory personnel independent of the 

card games department. Alternatively, changes to player tracking system 

parameters may be performed by card games supervisory personnel if sufficient 

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documentation is generated and the propriety of the changes is randomly verified by 

personnel independent of the card games department on a quarterly basis.

Comment (December): Remove the terms “supervisory” and state that the 

personnel must be authorized by the TGRA to perform this function. 

Response: Disagree. The standard recognizes the importance that parameter 

changes be performed or authorized by a supervisor. If the TGRA were to 

determine that its approval of the individuals possessing the authority to make 

such adjustments is warranted, it has the authority to establish a more stringent 

control. 

(6) All other changes to the player tracking system must be appropriately 

documented.

Comment (December): Standard is misplaced, should be in the IT section. 

Response: Agree, strike (i)(6). Note: (i)(7) then becomes (i)(6). 

Revised proposal as a result of December comment: 

(6) All other changes to the player tracking system must be appropriately 

documented.

(6) (7) Rules and policies for player tracking accounts including the awarding, 

redeeming and expiration of points shall be prominently displayed or available for 

customer review at the gaming operation. 

Justification: The MICS is currently silent on computerized player tracking systems for 

card games, which are becoming more prevalent in the industry and warrant the addition 

of the subject controls. The intent of the standards is to address the risk associated with 

automated systems that allow points to be redeemed for cash and merchandise. 

Proposed sub- section 542.9 (j) Accounting/Audit standards has been moved to proposed 

Revenue Audit 542.50 (b). 

(j) Accounting/Audit Standards

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Comment (December): Replace “accounting/auditing” with “revenue audit” 

throughout subsection (j) to clearly differentiate from the TGRA audit 

function.

Response: Disagree. With the exception of the compliance section of the 

MICS, no standards apply to the TGRA.

(1) The card games audit shall be conducted by personnel independent of the card 

games department.

(2) On a daily basis, audit/accounting personnel shall reconcile the amount indicated 

on the progressive sign/meter to the cash counted or received by the cage and the 

payouts made for each promotional progressive pot and pool. This reconciliation 

must be sufficiently documented (including substantiation of differences, 

adjustments, etc.).

(3) The following procedures shall be performed by accounting/audit personnel 

using the master game sheet prepared by the count team members for each day:

Comment (December): The NIGC is prescribing procedures to be used by 

the gaming operation and not standards. Revise item (3) as follows: “The 

gaming operation shall establish, subject to TGRA approval, procedures for 

the performance by accounting/audit personnel each day that address the 

following: (i) reconciliation of the drop to the applicable accountability 

documents; (ii) investigation and documentation of variances; (iii) 

recalculation of card game proceeds; (iv) verification of card game proceeds 

on the master game sheet; (v) audit of the master game sheet daily for 

completeness and correctness.”

Comment (December): Strike “procedures”.

Comment (December): Consolidate paragraphs (i) and (ii) in above 

comment.

Response: Disagree

(i) Reconcile the dollar amount of drop proceeds on the master game sheet to the 

dollar amount recorded in the applicable accountability document using, if 

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applicable, the transfer forms indicating all transfers in/out of the count room, both 

during and at the end of the count. Investigate and document any variance noted.

(ii) Recalculate card game proceeds (all funds received by the gaming operation as 

compensation for conducting the game) in total and by shift. For computerized 

master games sheets that total the count proceeds from each box, accounting 

personnel are to recalculate rake in total and by shift for one day each month, 

rather than daily.

(iii) Verify that the correct total of card game proceeds on the master game sheet is 

recorded in the accounting records. 

(iv) Examine the master game sheet for propriety of signatures.

Comment (December): Strike (iv), duplicates Drop and Count standard.

Comment (December): Standard does not include other auditing procedures 

such as verifying proper correction of errors.

Comment (December): Replace “master game sheet” with “appropriate 

accountability document” in paragraph (j)(3) and all sub-paragraphs.

Response: Disagree that this section needs to reiterate the controls specific to 

making corrections on the drop report (manual or computerized). Agree 

regarding the reference to master game sheet and striking (iv). 

Revised proposal as a result of December comments:

(3) The following procedures shall be performed by accounting/audit personnel 

using the appropriate document prepared by the count team members for each day:

(i) Reconcile the dollar amount of drop proceeds to the dollar amount recorded in 

the applicable accountability document using, if applicable, the transfer forms 

indicating all transfers in/out of the count room, both during and at the end of the 

count. Investigate and document any variance noted.

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(ii) Recalculate card game proceeds (all funds received by the gaming operation as 

compensation for conducting the game) in total and by shift. For computerized 

systems that total the count proceeds from each box, accounting personnel are to 

recalculate rake in total and by shift for one day each month, rather than daily.

Comment (January): Remove “, rather than daily”.

Response: Agree. Proposed revision is amended as follows:

Revised proposal as a result of January comment:

(ii) Recalculate card game proceeds (all funds received by the gaming operation as 

compensation for conducting the game) in total and by shift. For computerized 

master games sheets that total the count proceeds from each box, accounting 

personnel are to recalculate rake in total and by shift for one day each month.

(iii) Verify that the correct total of card game proceeds is recorded in the accounting 

records. 

(4) Monthly, accounting/audit personnel shall review all payouts for the 

promotional progressive pots, pools, or other promotions to determine proper 

accounting treatment. 

Comment (December): First, the accounting personnel review transactions 

on a daily basis; Second, this appears to be a function regularly done by 

compliance personnel, and we see no reason for the establishment of a 

procedure for the accounting department to audit their own work. The 

TGRA should determine how often these types of activities are audited, on 

what basis the audit should occur, and what additional specific standards 

should apply.

Comment (December): Replace “Monthly” with “At least monthly”.

Response: Disagree that the standard necessarily requires accounting to 

audit its own work. The accounting data originating from the gaming floor 

is audited daily by revenue audit; however, the revenue audit function is 

generally defined as the verification that the financial data is reliable and 

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valid. Data is considered to be valid if it is mechanically sound, e.g. adds up 

properly. Data is considered to be reliable if is effective in capturing the 

activity – is what it is represented to be. Several standards in the MICS 

require accounting/auditing personnel to review data or work product of 

data captured to confirm that it is appropriate. The control in question 

merely requires that the entries to the G/L booking promo payouts were 

recorded correctly. Noteworthy to this control is the fact that such 

transactions may require different accounting treatment. For example, a 

pool payout reduces a liability but a contest payout will typically affect an 

operating expense.

Response: Agree regarding the reference to at least monthly. Revised 

accordingly

Revised proposal as a result of December comment:

(4) At least monthly, accounting/audit personnel shall review all payouts for the 

promotional progressive pots, pools, or other promotions to determine proper 

accounting treatment. 

(5) Monthly, accounting/audit personnel shall perform procedures to ensure that 

payouts for the promotional progressive pots, pools, or other promotions are 

conducted in accordance with conditions provided to the customers.

Comment (December): Replace “Monthly” with “At least monthly”.

Response: Agree. 

Revised proposal as a result of December comment:

(5) At least monthly, accounting/audit personnel shall perform procedures to ensure 

that payouts for the promotional progressive pots, pools, or other promotions are 

conducted in accordance with conditions provided to the customers.

(6) 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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(7) For all contests, tournaments, promotional payouts (including payouts from 

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

following documentation shall be maintained:

(i) A copy of the information provided to customers describing the contest, 

tournament, promotional payout, drawing, and giveaway program (e.g., brochures, 

fliers);

(ii) Effective dates; and

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

Comment (December): Redundant to new subsection (h).

Response: Agree, (j)(7) and (i) – (iii) struck.

Revised proposal as a result of December comment:

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

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

following documentation shall be maintained:

(i) A copy of the information provided to customers describing the contest, 

tournament, promotional payout, drawing, and giveaway program (e.g., brochures, 

fliers);

(ii) Effective dates; and

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

(8) 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 the amounts withheld by the 

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gaming establishment, if applicable, were distributed in accordance with the 

contest/tournament rules.

Comment (December): Redundant to new subsection (h).

Response: Agree, (j)(8) struck. 

Revised proposal as a result of December comment:

(8) 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 the amounts withheld by the 

gaming establishment, if applicable, were distributed in accordance with the 

contest/tournament rules.

(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 additions/deletions made through an automated process related to actual card 

game play, for propriety.

(ii) Review exception reports including transfers between accounts. 

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

Comment (December): Redundant to new subsection (i).

Response: Agree, (j)(9) and (i) – (iii) struck.

Revised proposal as a result of December comment:

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

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

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

point additions/deletions made through an automated process related to actual card 

game play, for propriety.

(ii) Review exception reports including transfers between accounts. 

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

(10) At least annually, the computerized card games player tracking system (inhouse developed and purchased systems) 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 shall 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.

Comment (December): Standard is misplaced, should be in the IT section.

Response: Agree, (j)(10) struck. Note: (j)(11) then becomes (j)(7).

Revised proposal as a result of December comment:

(10) At least annually, the computerized card games player tracking system (inhouse developed and purchased systems) 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 

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

on the dollar amount wagered). The system shall 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.

(7) (11) Documentation (e.g., log, checklist, notation on reports, and tapes attached 

to original documents) evidencing the performance of card games audit procedures, 

the exceptions noted, and the follow-up of all card games audit exceptions shall be 

maintained,

Justification: The MICS are currently silent on accounting/audit standards for card 

games and promotional pots and pools, contests and tournaments, and 

computerized player tracking systems for card games. Experience has 

demonstrated that standards are needed to ensure effective accounting for the 

activities and revenues. The proposed standards are intended to address this need.

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