§542.33 What are the minimum internal control standards for surveillance for Tier B 

gaming operations? 

(a) The surveillance system shall be maintained and operated from a staffed surveillance 

room and shall provide surveillance over gaming areas. 

Justification: The deletions are considered duplications of the standards that follow. 

Comment (December): The term “surveillance room” requires a definition 

because very few casinos use a single room. The term “Surveillance Room” could 

mean the room where the operators watch the cameras, the DVR room where the 

equipment records, a review room where Surveillance shows the video to 

management, Surveillance training areas, etc. This becomes an issue in other parts 

of this document (i.e. part (b)) because the entrance to the “Surveillance Room” 

cannot be readily accessible as well as in other sections as listed below. We 

suggest defining the rooms where the operators conduct Surveillance and the 

areas where DVRs and other storage equipment is located as the “Surveillance 

Operation Rooms” This would allow Surveillance departments to locate the 

review rooms and training rooms in employee hallways. Further, for Tier B we 

recommend changing all references to “surveillance room” to “surveillance 

operation room”. For the purposes of this Section the term “surveillance 

operation room” means the area of the surveillance department where surveillance 

is taking place and/or where the surveillance equipment is located.” 

Response: Agree. Below definition has been added to 542.2 

Surveillance operation room means the area of the surveillance department where 

surveillance is taking place and/or where the surveillance equipment is located.

Revision based on December comment: 

(a) The surveillance system shall be maintained and operated from a staffed surveillance 

operation room and shall provide surveillance over gaming areas. 

Comment (January): Replace “surveillance operation room(s)” with “controlled 

area”. 

Response: Disagree. The requirement that the surveillance system be maintained 

and operated in an area dedicated for that purpose is deemed appropriate for Tier 

B gaming operations. The lesser standard “secured location” is appropriate for 

Tier A. The surveillance operation room is by definition a secured area. 

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Comment (January): Add “as designated by the TGRA” at the end of the 

paragraph. 

Response: Disagree. To be effective, the definition must establish, at a 

minimum, the scope of the term. The TGRA may, at its discretion, expand the 

definition. See below revision for additional specificity. 

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

Response: Agree. See below revision to the proposed regulation. 

Revision based on January comments: 

(a) The surveillance system shall be maintained and operated from a staffed surveillance 

operation room(s) and shall provide surveillance over gaming areas. 

(b) The entrance to the surveillance operation room shall be located so that it is not 

readily accessible by either gaming operation employees who work primarily on the 

casino floor, or the general public. 

Note (January): Consider removing remainder of the paragraph after accessible. 

Comment (January): Location is irrelevant to accessibility, provided the entrance 

is properly secured against unauthorized entry. 

Response: Agree. See below revision. 

Revision based on January comment and note: 

(b) The entrance to the surveillance operation room shall be appropriately secured to 

prevent unauthorized access. be located so that it is not readily accessible by either 

gaming operation employees who work primarily on the casino floor, or the general 

public.

(c) Access to the surveillance operation room shall be limited to surveillance personnel, 

designated employees, and other persons authorized in accordance with the surveillance 

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department policy. Such policy shall be approved by the Tribal gaming regulatory 

authority. The surveillance department shall maintain a sign-in log of other authorized 

persons entering the surveillance operation room. 

Justification: See 542.3 Compliance Section for general standard. 

Comment (January): Remove (c), redundant to (b). 

Response: Disagree. Paragraph (b) pertains to physical access; whereas, 

paragraph (c) pertains to the policy of determining who has the authority to access 

the room and certain documentation requirements. 

Comment (January): Replace “other authorized persons” in the second sentence 

with “surveillance personnel”. 

Response: Disagree. The intent of the sign-in log is to document extraordinary 

access, not routine access. 

(d) Surveillance operation room equipment shall have total override capability over all 

other satellite surveillance equipment located outside the surveillance operation room. 

(e) The surveillance system shall include date and time generators that possess the 

capability to display the date and time of recorded events on video and/or digital 

recordings. The displayed date and time shall not significantly obstruct the recorded 

view. 

(f) The surveillance operation room must be attended at all times by personnel 

trained in the use of the equipment, knowledge of the games, and house rules. When 

necessary, surveillance operation rooms may be unattended for periods of time not 

to exceed 1 hour in any 8-hour period to allow appropriate meal and rest breaks. 

The surveillance department shall strive to ensure staff is trained in the

use of the equipment, knowledge of the games, and house rules.

Justification: The revision is intended to add clarity and allow for limited periods that 

surveillance may remain unstaffed. 

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Comment (December): Remove the temporary unattended surveillance operation 

room allowance for Tier C only. 

Response: Agree. Language pertaining to the room being unstaffed during breaks 

is deleted for Tier C only. 

Comment (December): Change “must” to “shall”. 

Response: Agree. Proposal modified accordingly. 

Revision based on December comments: 

(f) The surveillance operation room shall be attended at all times by personnel 

trained in the use of the equipment, knowledge of the games, and house rules. The

surveillance department shall strive to ensure staff is trained in the use of the equipment, 

knowledge of the games, and house rules.

Note (January): Retain temporary unattended period allowance for Tier B only. 

Revision incorporating note: 

(f) The surveillance operation room must be attended at all times by personnel 

trained in the use of the equipment, knowledge of the games, and house rules. When 

necessary, surveillance operation rooms may be unattended for periods of time not 

to exceed 1 hour in any 8-hour period to allow appropriate meal and rest breaks.

(g) Each camera required by the standards in this section shall be installed in a manner 

that will prevent it from being readily obstructed, tampered with, or disabled by 

customers or employees. 

(h) Where a PTZ camera is used to observe gaming and gaming-related activities, 

the camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

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Justification: The revision is intended to establish the standard requiring PTZ cameras to 

be concealed, thereby precluding employees and customers from being able to detect the 

area being observed/recorded. 

Comment (December): Could be interpreted as a PTZ camera requirement. 

Replace “observe gaming and gaming-related activities” with “satisfy 

requirements of this part”. 

Response: Disagree with regard to interpretation. The standard is sufficiently 

clear that it does not require PTZ cameras to be used. Agree with regard to 

suggested replacement language, as modified. 

Revision based on December comment: 

(h) Where a PTZ camera is used to satisfy coverage requirements of this part, the 

camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

Comment (December): A smoked dome can reduce clarity in low-light areas. 

Response: Disagree. The objective of the control is to prevent patrons and 

employees from being able to determine the direction of the camera. A smoked 

dome was only one of the suggested means to satisfy the regulation. 

Comment (January): Any concealing material will reduce clarity. 

Comment (January): Concealing the direction of the camera plays a minimal role 

in reducing risk.

Comment (January): Coverage and clarity concerns greatly supersede any 

benefit of concealing direction. 

Response: On reconsideration, agree. Proposed standard will be struck. Note: 

subsections (i) – (w) then become (h) – (v). 

 

Revision based on January comments: 

(h) Where a PTZ camera is used to satisfy coverage requirements of this part, the 

camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

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(h) (i) (h) Each camera required by the standards in this section shall possess the 

capability of having its picture displayed on a monitor and recorded. The surveillance 

system shall include sufficient numbers of monitors and recorders to simultaneously 

display and record multiple gaming and count room activities, and shall record the views 

of all dedicated cameras and motion activated dedicated cameras. 

(i) (j) (i) Reasonable effort shall be made to repair each malfunction of surveillance 

system equipment required by the standards in this section within seventy-two (72) hours 

after the malfunction is discovered. The Tribal gaming regulatory authority shall be 

notified of any camera(s) that has malfunctioned for more than twenty-four (24) 

hours.

Justification: The standard was moved to (i) (2).

(1) In the event of a dedicated camera malfunction, the gaming operation and/or the 

surveillance department shall immediately provide alternative camera coverage or other 

security measures, such as additional supervisory or security personnel, to protect the 

subject activity. 

(2) The Tribal gaming regulatory authority shall be notified of any camera(s) that 

has malfunctioned for more than twenty-four (24) hours.

Comment (December): The notification threshold should be determined by the 

TGRA. Replace “for more than twenty-four (24) hours” with “in accordance with 

a time schedule established by the TGRA”. 

Response: Disagree. The MICS should be specific and, to the extent possible, 

incorporate objective criteria for determining compliance. To ensure that 

notification is made to the TGRA in a timely manner when a camera cannot be 

repaired, the regulation needs to specify a time period. 

Comment (December): Insert “required” to clarify that the standard applies only 

to cameras required by the standards in this section. 

 

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 Response: Agree. Proposed revision is as follows: 

Revision based on December comments: 

(2) The Tribal gaming regulatory authority shall be notified of any required 

camera(s) that has malfunctioned for more than twenty-four (24) hours.

Comment (January): Include alternative shorter period as determined by the 

TGRA. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Standard does not specify when notification is to occur. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Insert “within twenty-four (24) hours” after notified. 

Response: Disagree. See below revision that is intended to add clarity. 

Comment (January): Limit notification requirement to malfunctions resulting in 

inadequate coverage and clarity. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Insert “immediately” after notified. 

Response: Agree. See below revision to the proposed regulation. 

Revision based on January comments: 

(2) The Tribal gaming regulatory authority shall be notified immediately of any 

required camera(s) that has malfunctioned for more than twenty-four (24) hours (or 

a shorter period as determined by the Tribal gaming regulatory authority) resulting 

in coverage or clarity that does not meet the requirements of this part.

(j) Bingo. (1) The surveillance system shall possess the capability to monitor the 

bingo ball drawing device or random number generator, which shall be recorded 

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during the course of the draw by a dedicated camera with sufficient clarity to 

identify the balls drawn or numbers selected.

(2) The surveillance system shall monitor and record the game board and the 

activities of the employees responsible for drawing, calling, and entering the balls 

drawn or numbers selected.

Justification: Surveillance standards for Bingo will be addressed in 543.

(j) (k) Card games. The surveillance system shall monitor and record general activities 

in each card room with sufficient clarity to identify the employees performing the 

different functions. view customers, dealers, and activities on the card table 

surfaces.

Justification: The revisions are intended to clarify that the requirement extends to 

customers and the table surfaces. 

Comment (December): Here and throughout this section, is compliance 

determined by the identification requirements specified in the standard, or must 

the operation also meet the technical requirements in the Section 542.2 definition 

of sufficient clarity and in new paragraph (x)(1)(i)? 

Response: When the term “sufficient clarity” is used in the surveillance section, 

the technical requirements at 542.2 must be satisfied (digital – 30 fps and 4 CIF) 

and the coverage requirement must also be satisfied (customers, dealers, and table 

surface). 

(l) Progressive card games. (1) Progressive card games with a progressive jackpot of 

$25,000 or more shall be monitored and recorded by dedicated cameras that 

provide coverage of:

(i) The table surface, sufficient that the card values and card suits can be clearly 

identified;

(ii) An overall view of the entire table with sufficient clarity to identify customers 

and dealer; and

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(iii) A view of the posted jackpot amount.

(2) [Reserved]

Justification: The surveillance standards for progressive card games are being deleted as 

a result of enhancements to the Card Games section specific to controls governing the 

accounting for and the auditing of card game room activities. 

(k) (l) (m) Keno. (1) The surveillance system shall possess the capability to monitor 

the keno ball-drawing device or random number generator, which shall be recorded 

during the course of the draw by a dedicated camera with sufficient clarity to 

identify the balls drawn or numbers selected.

(1) A dedicated or motion-activated dedicated camera shall be utilized to monitor 

and record the following, both prior to and subsequent to the calling of a game: 

(A) Empty rabbit ears or wheel; 

(B) Date and time; 

(C) Game number; and 

(D) Full rabbit ears or wheel; 

(2) The recording of the rabbit ears or wheel during the course of the draw shall 

provide a legible identification of the numbers on the balls drawn. 

Justification: To revise the regulation to recognize that motion-activated dedicated 

cameras can satisfy the standard. 

(3) (2) The surveillance system shall record the keno ball-drawing device and the 

general activities in each keno game area and be capable of identifying with sufficient 

clarity to identify the employees performing the different functions. 

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(l) (m) (n) Pari-mutuel. The surveillance system shall monitor and record general 

activities in the pari-mutuel area, to include the ticket writer and cashier areas, with 

sufficient clarity to identify the employees performing the different functions. 

(m) (n) (o) Table games. (1) Operations with four (4) three (3) or more table games 

shall monitor and record the following: Except as otherwise provided in 

paragraphs (p)(3), (p)(4), and (p)(5) of this section, the surveillance system of 

gaming operations operating four (4) or more table games shall provide at a 

minimum one (1) pan-tilt-zoom camera per two (2) tables and surveillance must be 

capable of taping:

Comment (December): Remove reference to number of table games. There are 

no separate standards for operations with fewer than 3 table games in the 

proposed standards. 

Response: Disagree. The number of tables defines the applicability of the rule. If 

the gaming operation has fewer than three tables, the following standards do not 

apply. Striking the number would result in the regulation being applicable to 

properties that have less than three tables. 

(i) Each table game area, Wwith sufficient clarity to identify customers and dealers; and 

(ii) Each table game surface, with sufficient coverage and clarity to simultaneously 

view the table bank and determine the configuration of wagers, card values, and game 

outcome. 

Comment (December): Strike “simultaneously”. As written the standard could 

be interpreted to require a single high performance camera. 

Response: Disagree. Although the coverage requirement is typically satisfied 

with one overhead camera, the following is an amended proposed revision 

intended to add clarity: 

Revision based on December comment: 

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(ii) Each table game surface, with sufficient coverage and clarity to simultaneously 

view the table bank and determine the configuration of wagers, card values, and 

game outcome. Satisfaction of the coverage requirement may require multiple 

cameras of different types.

(iii) One (1) dedicated camera per table and one (1) pan-tilt-zoom camera per four 

(4) tables may be an acceptable alternative procedure to satisfy the requirements of 

this paragraph.

(2) Operations with three (3) or fewer table games. The surveillance system of 

gaming operations operating three (3) or fewer table games shall:

(i) Comply with the requirements of paragraph (p) (1) of this section; or

(ii) Have one (1) overhead camera at each table.

(3) Craps. All craps tables shall have two (2) dedicated cross view cameras covering 

both ends of the table.

(4) Roulette. All roulette areas shall have one (1) overhead dedicated camera 

covering the roulette wheel and shall also have one (1) dedicated camera covering 

the play of the table.

(5) Big wheel. All big wheel games shall have one (1) dedicated camera viewing the 

wheel.

Justification: The proposed standards are intended to provide greater latitude to gaming 

operations regarding the number, type and placement of surveillance cameras needed to 

provide sufficient coverage and clarity over the bank and table wagering activity. 

(n) (o) (p) Progressive table games. (1) Each Pprogressive table games with a 

progressive jackpot of $25,000 or more shall be monitored and recorded by dedicated 

cameras that provide coverage of: 

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Comment (December): Reconsider the reasonability of the $25,000 threshold. 

Response: Disagree. The threshold is derived from a similar standard in the 

Nevada MICS. 

(i) The table surface, sufficient that the card values and card suits can be clearly 

identified; 

(ii) An overall view of the entire table with sufficient clarity to identify customers and 

dealer; and 

(iii) A view of the progressive meter jackpot amount. If several tables are linked to the 

same progressive jackpot meter, only one meter need be recorded. 

(2) [Reserved] 

(o) (p) (q) Gaming machines. (1) Except as otherwise provided in paragraphs (r)(2) 

and (r)(3) of this section, Each gaming machine offering a payout of more than 

$250,000 shall be monitored and recorded by a dedicated camera(s) to provide coverage 

of: 

Comment (December): Strike “Each”, make “Gaming machine” plural. 

Response: Agree. Proposed revision amended as follows: 

Revision based on December comment: 

(1) Except as otherwise provided in paragraphs (r)(2) and (r)(3) of this section,

gaming machine Gaming machines offering a payout of more than $250,000 shall be 

monitored and recorded by a dedicated camera(s) to provide coverage of:

(i) All customers and employees at the gaming machine, and 

(ii) The face of the gaming machine, with sufficient clarity to identify the payout line(s) 

of the gaming machine. 

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(iii) The above requirements do not apply to wide area progressive gaming machines 

offering a payout of less than $3,000,000 and monitored by an independent vendor 

utilizing a linked, on-line progressive computer system.

Comment (December): By this language every machine that pays above $3 

million requires the dedicated cameras. The problem is that most machines with 

low base payouts of say $50k can still progress to well over $3 million. This 

exception would only apply to machines that ONLY pay up to and not beyond 

$2,999,999. All the machines that progress higher than that would require the 

additional coverage and that is a whole lot of machines!! See the next comment 

below for more clarity. Does the NIGC mean a BASE payout of $3 million? If so, 

that will work still because most machines’ base amount is less than $3 million. 

In our opinion this says is that if a machine pays less than $3 million the 

enhancements are not required but if the machine pays $3 million or more they 

are required. Well, this does not suit the industry at all. The machines start at a 

number much lower than $3 million and are able to progress to much more than 

$3 million. Thus, the Surveillance departments are not going to watch the 

progressive meters and install cameras when they reach $3 million, they must 

install cameras on ALL machines that can possibly progress to $3 million or 

more. That means two cameras for virtually every progressive machine in the 

every casino. It does not seem probable that a facility would install a camera 

when the threshold is met or only begin recording when it reaches the threshold. 

Either it is hung and recording or it is not. 

Response: Agree. The following amended revision is intended more clearly 

define when the enhanced coverage would be applicable to a wide area 

progressive machine. Whenever the probability of the payout exceeding the 

threshold is 25% or greater, the surveillance coverage will apply. Utilizing the 

formula that the Agency will provide, management will be able to determine at 

the time the device is put into service. 

Revision based on December comment: 

(o) (p) (q) Gaming machines. (1) Except as provided in paragraphs (q)(2) and (q)(3) 

of this section, g Gaming machines offering a payout of $250,000 or more shall be 

monitored and recorded by a dedicated camera(s) to provide coverage of: 

(i) All customers and employees at the gaming machine, and 

(ii) The face of the gaming machine, with sufficient clarity to identify the payout line(s) 

of the gaming machine. 

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Comment (January): Clarify that the standard is not necessarily a one 

camera/one machine requirement. 

Response: Agree. See below additional standard. 

Comment (January): Remove “by a dedicated camera(s)”. The coverage and 

clarity standards in the subsequent paragraphs are sufficient. 

Response: Disagree. Dedicated cameras ensure that a video record of the activity 

being observed will always be created. 

Comment (January): Machine electronic records and verification procedures 

greatly reduce the relevance of large payout surveillance controls. 

Response: Disagree. The control is common to the established gaming 

jurisdictions and recognizes that a corresponding relationship exist between the 

risk of compromise and the potential reward. Because of the size of the payouts 

in question, additional controls are warranted. 

Comment (January): Add paragraph (o)(1)(iii): “The coverage required in 

paragraphs (o)(1)(i) and (o)(1)(ii) does not require one dedicated camera per 

gaming machine if one dedicated camera is able to provide the required coverage 

for more than one gaming machine”. 

Response: Agree. The following standard is proposed to be added to the 

proposed revisions to section (o)(1): 

Added as a result of January comment: 

(iii) The coverage required in paragraphs (o)(1)(i) and (o)(1)(ii) does not require one 

dedicated camera per gaming machine if one dedicated camera is able to provide 

the required coverage for more than one gaming machine.

(2) The requirements in paragraph (o)(1) do not apply to wide area progressive 

gaming machines that are monitored by an independent vendor utilizing a linked 

on-line progressive computer system that have less than a 25% probability for a 

payout of $3,000,000 or more. 

Comment (January): Standard appears to reduce risk for the vendor rather than 

the gaming operation. 

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Response: Disagree. The controls are relevant to the gaming operation, which, 

notwithstanding any agreements that may exist between the gaming operation and 

a vendor, is ultimately responsible for making all wagering payouts to patrons. 

(3) The requirements in paragraph (o)(1) do not apply to in-house progressive 

gaming machines that have less than a 25% probability for a payout of $250,000 or 

more.

(4) Probability calculations for paragraphs (o) (2) and (o) (3) shall be performed 

using a formula provided by the Commission. 

Comment (December): The risk associated wide area progressive machines 

belongs to the vendor, but compliance responsibility and costs are the 

responsibility of the gaming operation.

Response: Disagree. The vendor has a contractual relationship with the gaming 

operation. Likewise, the patron enters into a wager with the gaming operation. 

Should be vendor fail to honor its commitment to the casino to pay a progressive 

jackpot, the casino is still obligate to make good the payout to the patron. 

Except for tribal gaming, the state gaming regulatory authorities typically require 

strict conditions are satisfied by the wide area progressive vendors, such a 

minimum liquidity standard. 

(2) In-house progressive machine. In-house progressive gaming machines offering a 

base payout amount (jackpot reset amount) of more than $100,000 shall be 

monitored and recorded by a dedicated camera(s) to provide coverage of:

(i) All customers and employees at the gaming machine; and

(ii) The face of the gaming machine, with sufficient clarity to identify the payout 

line(s) of the gaming machine.

(3) Wide-area progressive machine. Wide-area progressive gaming machines 

offering a base payout amount of $1 million or more and monitored by an 

independent vendor utilizing an on-line progressive computer system shall be 

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recorded by a dedicated camera(s) to provide coverage of: (Revised August 12, 

2005)

(i) All customers and employees at the gaming machine; and

(ii) The face of the gaming machine, with sufficient clarity to identify the payout 

line(s) of the gaming machine.

Justification: The revision is to reduce the surveillance requirements specific to in-house 

gaming machines without regard to whether the devices are linked to a wide area 

network. Specifically, the required dedicated camera coverage for large gaming machine 

payouts is being increased from $100,000 to $250,000, which is more consistent with 

other jurisdictions. 

Additionally, to clarify the exemption relevant to wide area progressive systems, the 

enhanced surveillance requirements are not applicable to actual payouts of less than 

$3,000,000 if the device is monitored by an independent vendor utilizing a linked, on-line 

progressive computer system. 

It is noteworthy that under the proposed standards for progressives, no enhanced 

monitoring or recording is required until such time as the progressive payout amount 

reaches the specified threshold. 

(4) Notwithstanding paragraph (r)(1) of this section, if the gaming machine is a 

multi-game machine, the Tribal gaming regulatory authority, or the gaming 

operation subject to the approval of the Tribal gaming regulatory authority, may 

develop and implement alternative procedures to verify payouts.

Justification: It is proposed that the standard be struck due to its ambiguity. 

(p) (q) (r) Cage and vault. (1) The surveillance system shall monitor and record a general 

overview of activities occurring in each cage and vault area with sufficient clarity to 

identify employees within the cage and customers and employees at the counter areas. 

Comment (December): Add identification of currency denominations to the 

sufficient clarity requirement. 

Comment (December): Add verification of transactions to the sufficient clarity 

requirement. 

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Response: Agree 

Revision based on December comments: 

(1) The surveillance system shall monitor and record a general overview of activities 

occurring in each cage and vault area with sufficient clarity to identify employees within 

the cage and customers and employees at the counter areas and to confirm cash 

transactions occurring between employees and between employees and customers. 

(2) Each cashier station shall be equipped with one (1) dedicated overhead camera 

covering the transaction area. 

(3) The surveillance system shall provide an overview of cash transactions. This 

overview should include the customer, the employee, and the surrounding area.

Justification: It is proposed that the standard be struck to eliminate redundancy with 

(p)(1) and (2) above. 

(s) Fills and credits. 

Justification: The separate sub-section for fills and credits has been incorporated into the 

Cage and Vault requirements. 

(3)(1) The cage or vault area in which fills and credits are transacted shall be monitored 

and recorded by a dedicated camera or motion activated dedicated camera that provides 

coverage with sufficient clarity to identify the chip values and the amounts on the fill and 

credit slips. Controls provided by a computerized fill and credit system may 

constitute an adequate alternative to viewing the amounts on the fill and credit slips.

(2) Controls provided by a computerized fill and credit system maybe deemed an 

adequate alternative to viewing the fill and credit slips.

Justification: The proposed revision is to facilitate clarity by consolidation of (2) into 

new (3) above. 

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(q) (r) (t) Currency and coin. Count rooms 

Justification: The title has been changed to provide clarity.

(1) The surveillance system shall monitor and record with sufficient clarity all areas 

where currency or coin may be stored or counted, including the hard count room, all 

doors to the hard count room, all scales and wrapping machines, and all areas 

where uncounted coin may be stored during the drop and count process.

Justification: The proposed revision is intended to better organize related standards by 

moving former (t) (2) (iii) to (r) (1). 

(3) The surveillance system shall provide for:

(2) (i) The surveillance system shall provide coverage of scales shall be of sufficient 

clarity to view any attempted manipulation of the recorded data. 

(ii) Monitoring and recording of the table game drop box storage rack or area by 

either a dedicated camera or a motion-detector activated camera.

Justification: To provide clarity regarding the applicability of the rule to all drop boxes, 

the above standard is being struck and consolidated into (2)(iv). 

(iii) Monitoring and recording of all areas where coin may be stored or counted, 

including the hard count room, all doors to the hard count room, all scales and 

wrapping machines, and all areas where uncounted coin may be stored during the 

drop and count process.

Justification: The proposed revision is intended to better organize related standards by 

moving former (t) (2) (iii) to new (r) (1). 

(iv) Monitoring and recording of soft count room, including all doors to the room, 

all table game drop boxes, safes, and counting surfaces, and all count team 

personnel. The counting surface area must be continuously monitored and recorded 

by a dedicated camera during the soft count.

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(v) Monitoring and recording of all areas where currency is sorted, stacked, 

counted, verified, or stored during the soft count process. 

Justification: To improve organization and clarity, the count room standards have been 

separated into those related to currency and to coin. 

(3)The surveillance system shall monitor and record with sufficient clarity all areas 

where currency may be stored or counted, and shall include the following: 

Comment (December): Sufficient clarity for this standard is not sufficiently 

defined. 

Comment (December): Propose separate standards for currency storage areas 

and currency counting areas. 

Response: Disagree with regard to sufficient clarity. The subsections (i) through 

(iv) define the coverage required. 

Disagree with regard to the separating of the standards applicable to storage and 

counting areas. The standards are sufficiently clear in defining the coverage 

applicable to each. 

(i)(iv) Soft count room Monitoring and recording of soft count room including all 

doors to the room, all game drop boxes, safes, and counting surfaces, and all count team 

personnel. 

(ii) The counting surface area must be continuously monitored and recorded by a 

dedicated camera during the soft count. 

Comment (December): Replace “monitored” with “displayed”.

Response: Agree. Suggest the regulation include both terms to ensure no 

misunderstanding. 

Revision based on December comment: 

(ii) The counting surface area must be continuously monitored/displayed and recorded 

by a dedicated camera during the soft count. 

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(iii) The drop box storage rack or area by either a dedicated camera or a motionactivated dedicated camera.

(iv) For count rooms utilizing currency counters and currency sorters, the 

surveillance system must possess the capability to monitor and record all areas 

where currency is sorted, stacked, counted, verified or stored during the count 

process. Coverage of the currency counting machines and currency sorting 

machines must be sufficiently clear to view the currency input, output and reject 

areas.

Comment (December): Testing, maintenance, and repair activities should be 

excluded from the standard. 

Response: Disagree. The proposed standard does not impose a surveillance 

coverage requirement specific to testing, maintenance and repair. 

(v) Monitoring and recording of all areas where currency is sorted, stacked, 

counted, verified, or stored during the soft count process.

 (u) Change booths. The surveillance system shall monitor and record a general 

overview of the activities occurring in each gaming machine change booth.

Justification: The above standard is proposed for deletion due to its diminished 

applicability in tribal gaming. 

(r) (s) (v) Video recording and/or digital record retention. (1) All video recordings 

and/or digital records of coverage provided by the dedicated cameras or motion-activated 

dedicated cameras required by the standards in this section shall be retained for a 

minimum of seven (7) days. 

Comment (December): Add “or such longer period as required by the TGRA”. 

Response: Agree. 

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Revision based on December comment: 

(r) (s) (v) Video recording and/or digital record retention. (1) All video recordings 

and/or digital records of coverage provided by the dedicated cameras or motion-activated 

dedicated cameras required by the standards in this section shall be retained for a 

minimum of seven (7) days, or such longer period that may be required by the Tribal 

gaming regulatory authority.

(2) Recordings involving suspected or confirmed gaming crimes, unlawful activity, or 

detentions by security personnel, must be retained for a minimum of thirty (30) days. 

Comment (December): Add “or such longer period as required by the Tribal 

gaming regulatory authority”. 

Response: Agree. 

Revision based on December comment: 

(2) Recordings involving suspected or confirmed gaming crimes, unlawful activity, or 

detentions by security personnel, must be retained for a minimum of thirty (30) days, or 

such longer period that may be required by the Tribal gaming regulatory authority.

(3) Duly authenticated copies of video recordings and/or digital records shall be provided 

to the Commission upon request. 

(s) (t) (w) Video library log. A video library log, or comparable alternative procedure 

approved by the Tribal gaming regulatory authority, shall be maintained to 

demonstrate compliance with the storage, identification, and retention standards required 

in this section. 

Justification: Above revisions are relevant to the general recommendation proposed for 

542.3. 

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(t) (u) (x) Malfunction and repair log. (1) Surveillance personnel shall maintain a log or 

alternative procedure approved by the Tribal gaming regulatory authority that 

documents each malfunction and repair of the surveillance system as defined in this 

section. 

(2) The log shall state the time, date, and nature of each malfunction, the efforts expended 

to repair the malfunction and the date of each effort, the reasons for any delays in 

repairing the malfunction, the date the malfunction is repaired, and where applicable, any 

alternative security measures that were taken. 

(3) The log must be retained for a minimum of 1 year after the date of the last entry 

in it.

Justification: The MICS are currently silent regarding the retention period for 

surveillance equipment malfunction logs. The above standard is intended to establish a 

one year retention period. 

(u) (v) (y) Surveillance log. (1) Surveillance personnel shall maintain a log of all 

surveillance activities. 

(2) Such log shall be maintained by surveillance operation room personnel and shall be 

stored securely within the surveillance department. 

(3) At a minimum, the following information shall be recorded in a surveillance log: 

(i) Date; 

(ii) Time commenced and terminated; 

(iii) Activity observed or performed; and 

(iv) The name or license credential number of each person who initiates, performs, or 

supervises the surveillance. 

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(4) Surveillance personnel shall also record a summary of the results of the surveillance 

of any suspicious activity. This summary may be maintained in a separate log. 

(5) The log must be retained for a minimum of 1 year after the date of the last entry 

in it.

Justification: The MICS are currently silent regarding the retention period for 

surveillance incident and activity logs. The above standard is intended to establish a one 

year retention period. 

(v) (w) Digital Surveillance System Standards (1) The digital surveillance equipment 

used to satisfy the surveillance standards in this Section must:

Comment (December): Replace “must” with “shall”. 

Response: Agree. 

Revision based on December comment: 

(1) The digital surveillance equipment used to satisfy the surveillance standards in 

this Section shall:

(i) Record and play back video at a minimum of 30 frames per second (FPS), full 

screen (4 common intermediate format CIF), in real time.

(ii) Produce visual resolution that is adequate to satisfy the sufficient clarity 

standards in this Section.

(iii) Have adequate storage capacity to maintain for a period of not less then seven 

(7) days, all images obtained from the video cameras.

(iv) Have a failure notification system that provides audible and visual notification 

of any failure in the surveillance system or the Digital Video Recording (DVR) 

media storage system.

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Comment (December): Camera failures are not always tied to alarms and this 

requirement might require major system installations. Provide an alternative such 

as daily verification of camera and DVR operation. 

Response: Disagree. The requirement is not inconsistent with gaming regulatory 

standards and the capability is common to most digital surveillance systems. 

Essentially involves the activation or deactivation of a parameter option. The 

standard should not impose an undue hardship on tribes with digital surveillance 

systems. 

Comment (January): The response does not adequately address the concerns 

expressed in the comment from the December meeting. Camera failures are not 

always tied to alarms and this requirement might require major system 

installations. Provide an alternative such as daily verification of camera and DVR 

operation. 

Response: Agree. Proposed regulation has been amended as follows: 

Revision based on January comment: 

(iv) Have a failure notification system that provides audible and visual notification 

of any failure in the surveillance system or the Digital Video Recording (DVR) 

media storage system. Alternatively, daily verification of the effective operation of

the surveillance system and DVR media storage system components is acceptable.

(v) Have a media storage system that is configured so that a failure of any single 

component will result in no loss of data from the media storage system.

(2) Access, or the ability to access, a digital surveillance system from any location 

outside of the surveillance operation room, must be approved by the Tribal gaming 

regulatory authority. Such transmissions must be effectively encrypted, firewalled 

on both ends, and password protected. 

Comment (January): Replace “must” with “shall”. 

Response: Agree. Proposed regulation is amended as follows: 

Revision based on January comment: 

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(2) Access, or the ability to access, a digital surveillance system from any location 

outside of the surveillance operation room, shall be approved by the Tribal gaming 

regulatory authority. Such transmissions shall be effectively encrypted, firewalled 

on both ends, and password protected. 

(3) All digital video disks or other storage media produced from the DVR system 

must contain the data with the time and date it was recorded superimposed, the 

media player and the software necessary to view the DVR images, as well as a video 

verification encryption code (also known as a watermark).

Comment (January): Replace “must” with “shall”. 

Response: Agree. Proposed regulation is amended as follows: 

Revision based on January comment: 

(3) All digital video disks or other storage media produced from the DVR system 

shall contain the data with the time and date it was recorded superimposed, the 

media player and the software necessary to view the DVR images, as well as a video 

verification encryption code (also known as a watermark).

(4) Any failure of a DVR storage media system must be repaired or replaced within 

8 hours of the failure.

Comment (December): This standard is unreasonable and nearly impossible to 

meet. It requires that a qualified repair person be available and both begin and 

complete the repair within 8 hours, and requires that every facility have 

replacement components on site for any system failures because ordering and 

shipping would certainly take the repair outside of the listed time period. Also, it 

is not limited to “equipment used to satisfy the standards in this section” and 

therefore includes DVR’s recording cameras that are not even MICS required, 

such as parking lot cameras. 

Comment (December): Add emphasis that the standard applies to total system 

failure, not individual component failure. 

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Response: Agree

Revision based on December comment: 

(4) In the event of a failure of a DVR storage media system (total system failure), 

the gaming operation should strive to repair or replace the equipment within 8 

hours of the failure. 

(5) All DVR equipment must be located in the surveillance operation room and the 

Surveillance Department shall be ultimately responsible for its proper operation 

and maintenance.

Justification: The MICS is currently silent regarding digital surveillance system 

standards. The NIGC surveillance standards within the MICS have not been updated to 

any material extent since 1999. The above standards are intended to codify the technical 

specifications that would be consistent with those of the established gaming jurisdictions. 

Comment (December): Make “surveillance operation room” plural.

 

Response: Agree. 

Comment (December): Strike responsibility requirement. A vendor can share 

responsibility for operation, and the IT department can have maintenance 

responsibilities. 

Response: Disagree. Although the surveillance department may engage an 

external party to perform maintenance and make repairs, responsibility for the 

department’s operation should rest with the management and staff of the 

surveillance department. 

Revision based on December comment: 

(5) All DVR equipment must be located in surveillance operation rooms and the 

Surveillance Department shall be ultimately responsible for its proper operation 

and maintenance.

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