AL FOR MOBILE GAMING DEVICES

The Snoqualmie Tribe supports the proposal to amend the technical standards to
address wireless gaming systems and communications. In doing so, these standards will
provide an effective baseline for the development of Tribal Internal Control Standards to
address the risks posed by these new gaming technologies. We would encourage the NIGC
to engage a Tribal Advisory Committee consisting of industry IT experts to ensure that the
appropriate risks of introducing wireless gaming systems are addressed and adequately
mitigated through adherence to the 25 CFR Part 547.18 standards.

Sincerely,

Quo T Caer

Sunny E. Clear,
Chairwoman
Snoqualmie Indian Tribe


Junel6, 2017

National Indian Gaming Commission
Attn: Vannice Doulou

1849 C St. NW

Mailstop #1621

Washington, DC 20240

Re: Comments inr mn:
2017 consultation session

Dear Commissioners,

The Snoqualmie Tribe appreciates the opportunity to provide comments on the
topics presented in the National Indian Gaming Commission’s Notice of Consultation dated
November 22, 2016. These consultation sessions demonstrate the NIGC’s ongoing
commitment to meaningful collaboration with Tribal governments and provide the
opportunity for valuable feedback in the development of federal policies that have Tribal
implications.

The comments below address the following topics identified in the November 22,
2016 Notice of Consultation: Draft Guidance on the Class III Minimum Internal Control
Standards, Developing a Strong Tribal Workforce through Training, and Technical
Standards for Mobile Gaming Devices.

INT

The Snoqualmie Tribe supports the NIGC’s proposal to suspend 25 C.F.R. Part 542,
while preserving the text in the Code of Federal Regulations. In doing so, the NIGC will not
disrupt existing Tribal-State Compacts and Tribal Gaming Ordinances that specifically
reference the part 542 regulations. This proposal also recognizes the agency’s class II
oversight authority under the Indian Gaming Regulatory Act while providing technical
guidance to Tribes in implementing Tribal Internal Control Standards (TICS) for class III
gaming operations.

The Snoqualmie Tribe commends the NIGC on drafting an effective guidance


document for public comment. The current draft addresses many of the emerging risks
that were not contemplated by the prior standards. In addition, by drafting the Class II]
MICS guidance to coincide with language in the part 543 Class II MICS, there will be greater
consistency in the development of effective TICS. The Snoqualmie Tribe is submitting the
following comments specific to the draft Class III Minimum Internal Control Standards §1 -
15 for the NIGC’s consideration:

Description

Section Ref.

Comments

General

A definition section similar to §542.2 and §543.2 of the existing
regulations should clarify terminology used throughout the
guidance document.

General

A section which outlines how Tribal governments are to comply
with this part similar to §543.3 of the class I] MICS should clarify
the applicability of these standards as voluntary guidance and
NIGC’s enforcement authority under this part.

Keno

§1(e)(3)()

§1(e)(3)(i) states that “at least two agents must authorize, sign,
and witness prize payouts above $1,200, or a lower threshold as
authorized by management and approved by the TGRA”.

The payout threshold for this section should be updated to $1,500
to coincide with the document retention standard in §1(1)(ii) and
the auditing revenue standard in §12(d)(1)(v). In addition, a
$1,500 threshold is consistent with §542.10(e)(6) of the existing
regulations and the IRS W2-G reporting threshold for Keno wins.

Gaming
Machines

§4

This section has multiple references to an independent test
laboratory but there are no technical standards in place for class
III gaming systems. Consider adding language that the Tribal
Gaming Regulatory Authority shall adopt appropriate technical
standards for class II] gaming systems.

Auditing
Revenue

§12

The following standards should be adopted as part of the §12
Auditing Revenue guidelines:
e Standards for Gaming Promotions and Player Tracking -
consistent with §543.24(d)(4) of the class II MICS
e Standards for Complimentary Services or Items —
consistent with §543.24(d)(5) of the class II MICS
¢ Standards for Patron Deposit Accounts - consistent with
§543.24(d)(6) of the class If MICS
e Standards for Lines of Credit - consistent with
§543.24(d)(7) of the class I] MICS
e Standards for Cage, Vault, Cash and Cash Equivalents -
consistent with §543.24(d)(9) of the class I] MICS
e Standards for Inventory - consistent with §543.24(d)(10)
of the class I] MICS



§12(d)(4)(iv) states that “for each drop period,
accounting/auditing employees shall compare the bill-in meter
reading to the total bill acceptor drop amount for the period.
Discrepancies shall be resolved before the
generation/distribution of gaming machine statistical reports”.

Language for this section should be updated to coincide with the
review and documentation requirements for variances. For
example, for each drop period, accounting/auditing employees
shall compare the bill-in meter reading to the total bill acceptor
drop amount for the period. The gaming operation must
establish, as approved by the TGRA, the threshold level at which a |
discrepancy must be reviewed to determine the cause. Any such
review must be documented and resolved before the
generation/distribution of gaming machine statistical reports.

Auditing
Revenue

§12(d)(4)(iv)

§13(d) which pertains to annual requirements should be removed
from the guidance document. The annual requirements contained
in part 542 will be preserved in the code of federal regulations for
those Tribes that have adopted such requirements for class II]
gaming. Including language for the submission of an Agreed Upon
Procedures report for class III gaming is unnecessary for
voluntary guidance.

Audit and

Accounting §13(d)

DEVELOPING ASTRON E THR

The Snoqualmie Tribe has utilized the NIGC Regional Training Conferences,
Regulating Gaming Technology Conferences and site specific trainings to heighten the
proficiency of our personnel. In our experience, the NIGC has developed an effective and
comprehensive training program which meets the needs of the Tribes and provides
tremendous value. The evolution of the NIGC training program toward a more hands-on
and practical approach has been evident over the years.

The Snoqualmie Tribe supports the development of a Learning Management System
which will assist in providing on-demand training as well as lessen the demand on training
budgets. We also support the development of knowledge reviews to enable us to assess
key outcomes and ensure that our teams are meeting the learning objectives of each
training offering. The Snoqualmie Tribe encourages the NIGC to continue to leverage
technology in their training program, including the use of live webinars which would allow
for a greater number of individuals to attend training sessions without the burden of travel.

The Snoqualmie Tribe recommends that the NIGC continue to engage Tribal leaders
and industry experts to lead training sessions at regional conferences and solicit feedback
on training topics. This enables participants to gain practical insight into industry best
practices.