§543.8 What are the minimum internal control standards for pull tabs? 

(a) Computer applications. For any computer application 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) Pull tab inventory. (1) Pull tab inventory (including unused tickets) shall be controlled 

to assure the integrity of the pull tabs. 

(2) Purchased pull tabs shall be inventoried and secured by a person or persons 

independent of the pull tab sales. 

(3) The issue of pull tabs to the cashier or sales location shall be documented and signed 

for by the person responsible for inventory control and the cashier. The document log 

shall include the serial number of the pull tabs issued. 

(4) Appropriate documentation shall be given to the redemption booth for purposes of 

determining if the winner purchased the pull tab from the pull tabs issued by the gaming 

operation. Electronic verification satisfies this requirement. 

543.8 (b) (5) & (6) have been moved to proposed Revenue Audit 543.50 (b) (1) and (2). 

(5) At the end of each month, a person or persons independent of pull tab sales and 

inventory control shall verify the accuracy of the ending balance in the pull tab 

control by reconciling the pull tabs on hand.

(6) A monthly comparison for reasonableness shall be made of the amount of pull 

tabs sold from the pull tab control log to the amount of revenue recognized.

(c) Access. Access to pull tabs shall be restricted to authorized persons. 

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(d) Transfers. Transfers of pull tabs from storage to the sale location shall be secured and 

independently controlled. 

(e) Winning pull tabs. (1) Winning pull tabs shall be verified and paid as follows: 

(i) Prize payouts of $600 or more, or a lesser amount established by the gaming 

operation, shall be verified by at least two persons, documentation required. Tribal 

gaming regulatory authority approval of this amount is recommended. 

(ii) Prize payouts over a predetermined amount shall require the signature and 

verification of two individuals, one of whom must be a member of supervisory or 

management staff independent of the pull tab department. This predetermined amount 

(Tribal gaming regulatory authority approval recommended) shall be authorized by 

management, documented, and maintained. 

(iii) Total payout shall be computed and recorded by shift. 

(iv) The winning pull tabs shall be voided so that they cannot be presented for payment 

again. 

543.8 (e) (2) has been moved to proposed Revenue Audit 543.50 (b) (3). 

(2) Personnel independent of pull tab operations shall verify the amount of winning 

pull tabs redeemed each day. 

(f) Accountability form. (1) All funds used to operate the pull tab game shall be recorded 

on an accountability form. 

(2) All funds used to operate the pull tab game shall be counted independently by at least 

two persons and reconciled to the recorded amounts at the end of each shift or session. 

Unverified transfers of cash and/or cash equivalents are prohibited. 

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(g) Standards for statistical reports. (1) Records shall be maintained, which include (for 

games sold in their entirety) a win-to-write hold percentage as compared to the expected 

hold percentage derived from the flare. Records shall also include win and write (sales) 

for each deal or type of game, for: 

(i) Each shift; 

(ii) Each day; 

(iii) Month-to-date; and 

(iv) Year-to-date or fiscal year-to-date as applicable. 

(2) A manager independent of the pull tab operations shall review statistical information 

at least on a monthly basis and shall investigate any large or unusual statistical 

fluctuations. These investigations shall be documented, maintained for inspection, and 

provided to the Tribal gaming regulatory authority upon request. 

543.8 (h) (1 (i)-(iv) have been moved to proposed Revenue Audit 543.50 (b) (4) 

(h) Electronic equipment. (1) If the gaming operation utilizes electronic equipment 

in connection with the play of pull tabs, then the following standards shall also 

apply.

(i) If the electronic equipment contains a financial instrument acceptor, then 

§543.21(e) and (f), §543.31(e) and (f), or §543.41(e) and (f) (as applicable) shall 

apply. 

(ii) If the electronic equipment uses a bar code or microchip reader, the reader shall 

be tested periodically to determine that it is correctly reading the bar code or 

microchip.

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(iii) If the electronic equipment returns a voucher to the player, then §543.7(f) (as 

applicable) shall apply.

(iv) If the electronic equipment utilizes patron account access cards for activation of 

play, then §543.7(g) (as applicable) shall apply. 

(2) [Reserved]

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